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                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554


                                            )                          
                                                                       
                                            )                          
                                                                       
                                            )                          
                                                                       
     In the matter of                       )                          
                                                                       
     Fiber Technologies Networks, L.L.C.,   )                          
                                                                       
     Complainant,                           )                          
                                                File No. EB-05-MD-014  
     v.                                     )                          
                                                                       
     North Pittsburgh Telephone Company,    )                          
                                                                       
     Respondent.                            )                          
                                                                       
                                            )                          
                                                                       
                                            )                          
                                                                       
                                            )                          


                          MEMORANDUM OPINION AND ORDER

   Adopted: February 23, 2007 Released: February 23, 2007

   By the Chief, Enforcement Bureau:

   I. introduction

    1. In this Memorandum Opinion and Order, we grant a Complaint filed by
       Fiber Technologies Networks, L.L.C. ("Fibertech") against North
       Pittsburgh Telephone Company ("NPTC"), pursuant to section 224 of the
       Communications Act of 1934, as amended ("the Act") and sections
       1.1401-1.1418 of the Commission's rules. The Complaint alleges that
       NPTC violated section 224 by denying Fibertech access to NPTC's poles
       for the placement of Fibertech's attachments. Fibertech requests that
       the Commission grant it immediate access to NPTC's poles, and require
       NPTC to take all actions necessary to accommodate Fibertech's access.
       For the reasons stated below, we grant Fibertech's Complaint and order
       NPTC to provide Fibertech immediately with nondiscriminatory access to
       NPTC's poles.

   II. FACTUAL AND REGULATORY background

    2. Fibertech provides facilities-based fiber-optic telecommunications
       capacity and services. Fibertech holds four Certificates of Public
       Convenience ("Certificates") from the Pennsylvania Public Utilities
       Commission ("PaPUC") to provide "telecommunications services to
       business customers, other carriers and public and private
       institutions." The Certificates authorize Fibertech to "offer, render,
       furnish, or supply telecommunications services" "to the public" "in
       the Commonwealth of Pennsylvania" as (1) "a Reseller of Interexchange
       Toll Services;" (2) "a Competitive Access Provider;" and (3) "a
       Facilities-Based Interexchange Carrier."

    3. Fibertech has filed tariffs with the PaPUC ("Tariffs") offering to
       provide a variety of telecommunications services throughout the
       Commonwealth of Pennsylvania, including, for example: (i) intrastate
       interexchange resale toll services, such as switched and dedicated
       long distance services for business customers; (ii) competitive access
       services, such as trunk-side transport termination, local transport,
       SS7 out-of-band signaling, 800 data base access, and dedicated
       high-speed digital services; and (iii) intrastate facilities-based
       interexchange services, such as interLATA switched long-distance
       service and intraLATA switched long-distance service.

    4. NPTC is a "local exchange carrier" and a "utility" within the meaning
       of section 224(a)(1) of the Act. It provides facilities-based,
       switched access, telecommunications services to subscribers in
       portions of Allegheny, Armstrong, Butler, and Westmoreland Counties,
       Pennsylvania.  As a "utility," NPTC must provide "a cable television
       system or any telecommunications carrier" with "nondiscriminatory
       access to any pole, duct, conduit, or right-of-way owned or controlled
       by it," unless it can show that a denial of access is justified due to
       "insufficient capacity" or "for reasons of safety, reliability and
       generally applicable engineering purposes."

    5. In April and May 2005, Fibertech sought access to NPTC's poles to
       extend into NPTC's service territory a fiber optic network already
       operating elsewhere in Pennsylvania. Fibertech explained that it
       sought to build in NPTC's service territory a network extension of
       Fibertech's Pittsburgh-area network, enabling Fibertech to satisfy the
       needs of an initial end-user customer as well as "many other future
       customers," pursuant to Fibertech's Certificates and Tariffs.

    6. NPTC promptly denied Fibertech's request for access to NPTC's poles.
       NPTC construed the information supplied by Fibertech as showing that
       Fibertech was planning to (i) construct a private network for only one
       customer rather than a common carriage network available to the
       public, and (ii) offer only dark fiber rather than lit fiber. Thus, in
       NPTC's view, Fibertech was not a "telecommunications carrier" with
       pole access rights under section 224(f)(1) of the Act.

    7. On July 8, 2005, Fibertech filed the instant Complaint requesting that
       the Commission grant Fibertech immediate rights of access to NPTC's
       poles. The key question presented by Fibertech's Complaint is whether
       Fibertech is a "telecommunications carrier" with statutory rights of
       access to NPTC's poles under section 224(f)(1) of the Act. Answering
       that question requires examination of certain statutory and common law
       definitions described below.

    8. NPTC must provide Fibertech access to NPTC's poles if Fibertech is a
       "telecommunications carrier" in NPTC's territory. The Act defines
       "telecommunications carrier," in pertinent part, as "any provider of
       telecommunications services ...," and specifies that "[a]
       telecommunications carrier shall be treated as a common carrier under
       this Act only to the extent that it is engaged in providing
       telecommunications services." The term "telecommunications service" is
       defined as "the offering of telecommunications for a fee directly to
       the public, or to such classes of users as to be effectively available
       directly to the public, regardless of the facilities used."
       "Telecommunications" is defined as "the transmission, between or among
       points specified by the user, of information of the user's choosing,
       without change in the form or content of the information as sent and
       received."

    9. In interpreting those statutory definitions, the U.S. Court of Appeals
       for the D.C. Circuit (D.C. Circuit) affirmed the Commission's
       conclusions that (i) the term "telecommunications service" "is
       intended to encompass only telecommunications provided on a common
       carrier basis," and (ii) the term "telecommunications carrier," which
       was added to the Act in 1996, has essentially the same meaning as the
       pre-existing term "common carrier." Courts construing "common carrier"
       have held, inter alia, that "the primary sine qua non of common
       carrier status is a quasi-public character, which arises out of the
       undertaking to carry for all people indifferently;" and a "second
       prerequisite to common carrier status" is that "`customers transmit
       intelligence of their own design and choosing." Such offering of
       service indiscriminately to the public may be either a wholesale
       offering to other carriers or a retail offering to end users.

   III. DISCUSSION

          A. Fibertech Has Established A Prima Facie Case That It Is A
             "Telecommunications Carrier" With A Right Of Access To NPTC's
             Poles Under Section 224(f)(1) Of The Act

   10. In a case such as this challenging a utility's denial of access to its
       poles, section 1.1409(b) of our rules provides that the complainant
       bears the burden of establishing a prima facie case that the denial of
       access violates section 224(f) of the Act. Once the complainant
       establishes a prima facie case, the respondent utility has the burden
       of proving that its denial was lawful. Therefore, Fibertech bears an
       initial burden to establish a prima facie case that it is a
       "telecommunications carrier" with a right of access to NPTC poles
       within the meaning of the Act. As discussed below, we conclude that
       Fibertech has met that burden by showing that it possesses valid state
       authorizations to provide telecommunications services, and has filed
       state tariffs offering such services to the public.

   11. Fibertech has offered proof of its status as a "telecommunications
       carrier" in NPTC's territory by submitting in the record (i) its
       Certificates from the PaPUC authorizing Fibertech to "offer, render,
       furnish, or supply telecommunications services" as a reseller and
       facilities-based carrier of interexchange toll services ("IXC"), and
       as a competitive access provider ("CAP"); and (ii) the
       telecommunications service Tariffs that it has publicly filed with the
       PaPUC pursuant to its authorizations to provide intrastate
       telecommunications services. We find that the decisions of the PaPUC
       to issue Certificates of Public Convenience authorizing Fibertech to
       provide intrastate "telecommunications services" and to allow
       Fibertech to publish its Tariffs reflect judgments by an expert
       regulatory agency that the services set forth in Fibertech's Tariff
       constitute "telecommunications services" and that Fibertech will offer
       those services for a fee to the public. Such judgments suffice to
       establish a prima facie case.

   12. NPTC observes that the Pennsylvania statutory provisions defining who
       is a "telecommunications carrier" providing "telecommunications
       service" are not identical to the definitions of those terms provided
       in the Act. An examination of the Pennsylvania definitions, however,
       reveals that they are, in fact, very similar to the federal
       definitions, although not identical. The applicable Pennsylvania
       statute defines "telecommunications carrier" as "[a]n entity that
       provides telecommunications services subject to the jurisdiction of
       the [PaPUC]," and defines "telecommunications service" as "[t]he
       offering of the transmission of messages or communications for a fee
       to the public." Like the Act, the Pennsylvania statute provides that,
       to qualify as a "telecommunications carrier" providing
       "telecommunications service," an entity must offer transmission of
       communications for a fee to the public.

   13. Recognizing that the Pennsylvania statute provides that a
       "telecommunications carrier" is subject to the jurisdiction of the
       PaPUC, NPTC focuses on the definition of "public utility" in S 102 of
       the statute, which identifies entities regulated by the PaPUC. Section
       102 states, in pertinent part, that a "Public Utility" is "(1) Any
       person or corporations now or hereafter owning or operating in this
       Commonwealth equipment or facilities for: ... (vi) Conveying or
       transmitting messages or communications ... by telephone or telegraph
       or domestic public land mobile radio service ... for the public for
       compensation." NPTC argues, based on this statutory language, that
       Pennsylvania law is broader than the Act "in that it concerns not only
       the transmitting of communications, but also the conveying of
       communications (as well as `messages')," and it is "narrower in that
       it applies only to entities which own or operate equipment or
       facilities."

   14. NPTC has not shown, however, that these alleged distinctions
       constitute material differences between the definitions of
       "telecommunications carrier" and "telecommunications service" provided
       under Pennsylvania and federal law; and we discern none. Moreover,
       NPTC provides no reason to conclude, based on these alleged
       definitional distinctions, that Fibertech does not qualify as a
       "telecommunications carrier" under the Act, even though Fibertech
       qualifies as a "telecommunications carrier" and "public utility"
       authorized to provide "telecommunications services" under Pennsylvania
       law. For these reasons, we reject NPTC's suggestion that Fibertech is
       not entitled to rely on the decisions of the PaPUC to make a prima
       facie showing that Fibertech is a "telecommunications carrier" with
       pole attachment rights under section 224(f) under the Act.

   15. Our reliance on the PaPUC's decisions in assessing whether Fibertech
       has made a prima facie showing of its status as a "telecommunications
       carrier" finds support in cases addressing the prerequisites for the
       analogous process of establishing an entity's status as a "cable
       television system" with pole attachment rights under section 224(f).
       In Paragon Cable Television Inc. v. FCC, the D.C. Circuit upheld a
       Commission ruling that possession of a valid cable franchise is a
       reasonable precondition for establishing pole attachment rights. In so
       holding, the D.C. Circuit found that the Commission could apply a
       "presumption of validity" to decisions by the local franchising
       authority concerning the attacher's status as an approved franchisee.
       Similarly, in Texas Util. Elec. Co v. FCC, the D.C. Circuit upheld a
       Commission ruling that section 224 of the Act confers jurisdiction
       over those pole attachments within the franchise service area defined
       by the local franchise authority. These cases suggest that attachers
       are entitled to rely on decisions by responsible regulatory agencies,
       such as franchise authorities in the case of cable system attachers,
       and public utility commissions in the case of telecommunications
       carriers, in establishing their status as entities entitled to pole
       access under section 224(f) of the Act.

   16. Based on the foregoing, we conclude that Fibertech's possession of
       valid state authorizations to provide telecommunications services,
       together with its associated state Tariffs, constitute presumptive
       evidence of its status as a "telecommunications carrier" within the
       meaning of the Act. Therefore, in our view, Fibertech has made a prima
       facie showing that it is a "telecommunications carrier" entitled to
       nondiscriminatory access to NPTC's poles under section 224(f)(1) of
       the Act.

     A. NPTC Has Failed to Show That Its Denial of Access Was Lawful

   17. Because Fibertech has established a prima facie case, the burden
       shifts to NPTC to demonstrate that its denial of access was lawful.
       NPTC cites several factors that purportedly show that Fibertech does
       not qualify as a "telecommunications carrier" with a right to attach
       to NPTC's poles under section 224 of the Act. We have examined each of
       the factors offered by NPTC and conclude, for the reasons set forth
       below, that NPTC has failed to show that Fibertech is not a
       "telecommunications carrier" under the Act, and thus it cannot justify
       its denial of access on that basis.

      1. Pursuant to its intrastate CAP and IXC Tariffs, Fibertech holds
         itself out directly to the public to provide telecommunications for
         a fee in NPTC's service territory

   18. NPTC defends its denial of access on the ground that mere possession
       of authorizations to provide telecommunications service, and the
       filing of tariffs pursuant thereto, do not establish that Fibertech is
       acting as a "telecommunications carrier" in NPTC's service territory.
       NPTC seems to suggest that Fibertech cannot qualify as a
       "telecommunications carrier" unless and until it is actually supplying
       telecommunications service to at least one customer in NPTC's
       territory. NPTC also contends that provision of dark fiber is not a
       "telecommunications service," so Fibertech cannot rely on its
       provision of dark fiber to qualify as a "telecommunications carrier."
       We reject both of these assertions.

   19. First, we reject NPTC's contention that Fibertech must show that it is
       actually supplying telecommunications service to a customer in NPTC's
       territory to qualify as a "telecommunications carrier" with a right of
       attachment under section 224 of the Act. The Act defines
       "telecommunications carrier" as any "provider of telecommunications
       services," and defines "telecommunications service" as the
       indiscriminate "offering of telecommunications." These two
       definitions, read together, indicate that a "telecommunications
       carrier" is a carrier that offers to provide telecommunications on a
       common carrier basis, regardless of whether the carrier has actually
       supplied such service to a customer in the past. To hold otherwise
       would lead to the anomalous, Catch-22 result that an entity could not
       establish its identity as a "telecommunications carrier" for purposes
       of obtaining access to poles under section 224(f)(1) unless it was
       already supplying telecommunications service to the public, which
       might not even be possible without first obtaining access to poles.

   20. Turning to the record before us, we find that Fibertech is, in fact,
       offering to provide telecommunications service in NPTC's territory
       within the meaning of the Act. Specifically, Fibertech's PaPUC
       authorizations to provide telecommunications services as a CAP and an
       IXC on a statewide basis, together with its Tariffs, establish that
       Fibertech offers to provide a variety of telecommunication services to
       the public for a fee in NPTC's territory. Indeed, the very term
       "tariff" means an offering to provide service; and the text of
       Fibertech's Tariffs reflects that meaning. For example, Fibertech's
       CAP Tariff and Switched Access Tariff each set forth "the service
       offerings, rates, terms and conditions applicable to the furnishing of
       ... services for connection to communications facilities of
       [Fibertech] to customers." Therefore, NPTC's contention that Fibertech
       is not a "telecommunications carrier" because Fibertech is not yet
       actually supplying service to any customers in NPTC's territory lacks
       merit.

   21. NPTC also asserts, without support, that Fibertech intends to serve
       only a single customer in NPTC's territory, which, in NPTC's view,
       disqualifies Fibertech as a "telecommunications carrier." NPTC's
       assertions are contradicted by statements from Fibertech's
       representatives affirming that (i) the network segment Fibertech seeks
       to provide to its initial customer will be part of a wider network
       that Fibertech plans to use to serve many future customers and (ii)
       Fibertech intends to provide a variety of telecommunications services
       in NPTC's service area, including "lit" long distance and local
       dedicated transport service. Based on this record, we find that NPTC's
       unsubstantiated suppositions about Fibertech's intentions are
       insufficient to rebut Fibertech's prima facie showing of its status as
       a telecommunications carrier.

   22. We also find unavailing NPTC's attempt to justify its denial of access
       based on Fibertech's plans to provide "dark fiber" facilities to its
       initial customer in NPTC's service area. According to NPTC, dark fiber
       does not constitute a "telecommunications service" under the Act, and
       therefore Fibertech has no right to attach to NPTC's poles for the
       purpose of providing dark fiber. This argument overlooks the fact that
       Fibertech, through its Tariffs, offers to provide a variety of "lit"
       services in NPTC's area that indisputably qualify as
       "telecommunications services" under the Act. Thus, regardless of the
       status of dark fiber under the Act - an issue we need not and do not
       address here - Fibertech has established that it qualifies as a
       "telecommunications carrier" with a right of access under section
       224(f) based on these "lit" service offerings.

   23. This conclusion is supported by the Supreme Court's decision in NCTA
       v. Gulf Power, which held, in an analogous context, that the
       protections of section 224 continue to apply to attachments by cable
       systems, even if the attachments are simultaneously used to provide
       both cable service and a non-cable service, such as high-speed
       Internet access. The Court reasoned that an attachment by a cable
       television company providing only cable service is an "attachment by a
       cable television system," subject to section 224, and that the
       addition of another service, such as Internet access service, "does
       not change the character of the attaching entity - the entity the
       attachment is `by.'" "And this," declared the Court, "is what matters
       under the statute." Likewise, Fibertech, having established its status
       as a telecommunications carrier with a right of access under section
       224(f) based on its lit service offering, would not lose that status
       by offering non-telecommunications services over the same attachment.
       As long as Fibertech is offering to provide at least one
       telecommunications service via its pole attachments, its additional
       offering of an alleged non-telecommunications service has no impact on
       its pole attachment rights.

      1. Fibertech offers to provide "telecommunications" rather than
         "information" services pursuant to its intrastate Tariffs

   24. NPTC also claims that denial of access to its poles is justified
       because Fibertech intends to provide to its initial customer "an
       information (or data transmission) service rather than what the FCC
       views as a `telecommunications service.'" In support, NPTC states that
       the Commission has deemed Internet access an "information service"
       rather than a "telecommunications service." As explained below, we
       reject this argument because NPTC has failed to show that Fibertech
       offers an information service in NPTC's territory.

   25. NPTC is correct that the Commission has classified as "information
       service" an integrated service that combines transmission with the
       data storage, manipulation, processing, and retrieval portion, i.e.,
       the Internet service provider ("ISP") portion of an Internet access
       service. The ISP portion of an Internet access service typically
       provides end users with a comprehensive capability for manipulating
       information using the Internet, including applications such as web
       browsing, file transfers, e-mail access, Usenet newsgroups, and Domain
       Name System access. The Commission has also recognized that the
       "telecommunications" component of an Internet access service can be
       "part and parcel" of an integrated Internet access service offering,
       or it can be offered separately from the ISP portion of the service
       and consist solely of a transparent transmission path, with no changes
       to the form or content of the transmitted information. Carriers can
       choose to offer this transmission component as a telecommunications
       service on a stand-alone, wholesale, common carrier basis to ISPs, who
       then use that service as an input for the wireline broadband Internet
       access that the ISPs, in turn, offer to their own end user customers.
       Given the foregoing, the Commission has held that whether a service is
       a "telecommunications service" or an "information service" turns on
       the nature of the functions the purchaser is offered. The
       determinative question, briefly put, is: does the service offering
       involve only a transparent transmission path, with no changes to the
       form or content of the transmitted information; or does it involve
       data storage, manipulation, processing, and retrieval?

   26. Applying that standard here, we find that the services that Fibertech
       offers through its PaPUC Tariffs are "telecommunications services,"
       not "information services." NPTC has not identified, and we cannot
       independently discern, any provision in any of Fibertech's various
       Tariffs that offers to provide the ISP portion of Internet access
       service, i.e., data storage, manipulation, processing, and retrieval.
       Instead, in its applicable Tariffs, Fibertech offers only transparent
       transmission paths, with no changes to the form or content of the
       transmitted information in NPTC's service territory. Specifically,
       Fibertech offers to provide only the underlying transmission (or
       "telecommunications") typically used by ISPs and other information
       service providers in the provision of retail Internet access and other
       data processing services to subscribers. As we found in the Wireline
       Broadband Order, "carriers may choose to offer this type of
       transmission as a common carrier service if they wish. In that
       circumstance, it is of course a telecommunications service."
       Accordingly, Fibertech's provision of tariffed service to its initial
       customer provides no basis for NPTC's assertion that Fibertech is not
       a "telecommunications carrier" with pole access rights under section
       224(f)(1) of the Act.

     A. NPTC's Request to Dismiss the Complaint on Procedural Grounds Lacks
        Merit

   27. Finally, NPTC argues that the Complaint, filed on July 8, 2005, should
       be dismissed as defective because it "fails to overcome the reasons
       given for dismissal" of the original complaint that Fibertech's filed
       on the June 24, 2005. Staff had dismissed the original complaint
       without prejudice on procedural grounds, citing Fibertech's failure to
       comply fully with the Commission's pleading rules. When Fibertech
       filed its revised Complaint on July 8, 2005, staff found it to be
       adequate and accepted it for filing. Staff subsequently allowed
       Fibertech to supplement its pleadings with further documentation, and
       directed both parties to provide additional briefing of certain legal
       issues.

   28. We find that dismissal of the re-filed complaint is unwarranted here.
       Although Fibertech should have included with its Complaint all of the
       additional documentation it reasonably believed was necessary to
       support its factual allegations, NPTC has shown absolutely no
       prejudice by Fibertech's later inclusion of these materials in the
       record. We therefore deny NPTC's request to dismiss the Complaint for
       failure to comply with the Commission's rules.

   IV. Conclusion

   29. For the reasons stated above, we find that (i) Fibertech has carried
       its burden to establish a prima facie case demonstrating its
       entitlement to attach to poles, ducts, conduits and rights-of-way
       owned or controlled by NPTC, and (ii) NPTC has failed to carry its
       burden of proof that denial of access was lawful on the alleged ground
       that Fibertech is not a "telecommunications carrier" offering to
       provide "telecommunications services," as those terms are defined in
       the Act. We therefore find that Fibertech is a "telecommunications
       carrier" entitled to pole attachments under section 224(f), and grant
       the relief requested in the Complaint.

   V. ordering clauseS

   30. Accordingly, IT IS ORDERED, pursuant to sections 1, 4(i), 4(j), and
       224 of the Communications Act of 1934, as amended, 47 U.S.C. SS 151,
       154(i), 154(j), and 224, and sections 0.111 and 1.1401-1.1418 of the
       Commission's rules, 47 C.F.R. SS 0.111 and SS 1.1401-1.1418, that the
       Complaint IS GRANTED.

   31. IT IS FURTHER ORDERED, pursuant to sections 1, 4(i), 4(j), and 224 of
       the Communications Act of 1934, as amended, 47 U.S.C. SS 151, 154(i),
       154(j), and 224, and sections 0.111 and 1.1401-1.1418 of the
       Commission's Rules, 47 C.F.R. SS 0.111 and 1.1401-1.1418, that, to the
       extent that Fibertech continues to seek access to NPTC's facilities,
       Fibertech and NPTC SHALL PROMPTLY NEGOTIATE IN GOOD FAITH
       nondiscriminatory terms and conditions of access and maximum just and
       reasonable rates for pole attachments in accordance with 47 U.S.C. S
       224 and the Commission's rules.

   32. IT IS FURTHER ORDERED, pursuant to sections 1, 4(i), 4(j), and 224 of
       the Communications Act of 1934, as amended, 47 U.S.C. SS 151, 154(i),
       154(j), and 224, and sections 0.111 and 1.1401-1.1418 of the
       Commission's Rules, 47 C.F.R. SS 0.111 and 1.1401-1.1418, that, to the
       extent that Fibertech continues to seek access to NPTC's facilities,
       NPTC SHALL: (i) immediately commence survey and engineering work on
       the poles in NPTC's service area to which Fibertech seeks to attach;
       (ii) grant access to NPTC's poles without a formal agreement in the
       event NPTC fails to complete a just and reasonable pole attachment
       agreement within 60 days from the date of this Order; and (iii)
       commence make-ready/facilities arrangements no later than 15 days from
       the date of this Order.

   FEDERAL COMMUNICATIONS COMMISSION

   Kris Anne Monteith

   Chief, Enforcement Bureau

   Complaint of Fiber Technologies Networks, LLC, File No. EB-05-MD-014
   (filed Jul. 8, 2005) ("Complaint").

   47 U.S.C. S 224.

   47 C.F.R. SS 1.1401-1.1418.

   See, e.g., Complaint at 5, P 19 and 7, P 29.

   Complaint at 8-9, P 34.

   See, e.g., Complaint at 1, P 2; Response to Complaint filed by NPTC, File
   No. EB-05-MD-014 (filed Aug. 10, 2005) ("Response") at 1, P 2.

   Order of the PaPUC dated September 28, 2001 approving Fibertech's
   certification applications in PaPUC Docket A-311101, A-311101 F0002,
   A-311101 F0003, and A-311101 F0004 ("PaPUC Fibertech Order") at 2,
   attached to Letter dated October 25, 2005 from J.D. Thomas, Counsel for
   Fibertech, to Marlene Dortch, Federal Communications Commission, Office of
   the Secretary, File No. EB-05-MD-014 ("Fibertech October 25 Letter"). See
   Complaint at 4-5, P 17; Response at 1, P 2 n.1; 7-8, P 17. See also
   Certificates of Public Convenience granted by the PaPUC ("Certificate
   A-311101," "Certificate A-311101 F0002," "Certificate A-311101 F0003,"),
   attached to Fibertech October 25 Letter, and ("Certificate A-311101
   F0004"), attached to Letter dated August 15, 2006 from Genevieve D. Sapir
   to Marlene H. Dortch, Secretary, Federal Communications Commission, File
   No. EB-MD-014 ("Fibertech Aug. 15 Letter").

   Certificate A-311101, attached to Fibertech October 25 Letter.

   Certificate A-311101 F0003, attached to Fibertech October 25 Letter.

   Certificate A-311101 F0004, attached to Fibertech Aug. 15 Letter.
   Fibertech has also received a Certificate from the PaPUC authorizing it to
   "offer, render, furnish, or supply telecommunications services" as a
   "Reseller and Facilities-Based Competitive Local Exchange Carrier to the
   public within the service territory of Verizon Pennsylvania, Inc."
   Certificate A-311101 F0002, attached to Fibertech October 25 Letter.

   See Letter dated November 30, 2005 from J.D. Thomas, David L. Sieradzki,
   Genevieve D. Sapir, Counsel for Fibertech, to Barbara Esbin, Market
   Disputes Resolution Division, Enforcement Bureau, File No. EB-05-MD-014
   ("Fibertech Nov. 30 Letter"), attaching Fibertech's PaPUC Tariffs and a
   Declaration of Frank Chiaino, Executive Vice President and Chief Operating
   Officer of Fibertech Networks, ("Chiaino Declaration"), which describes
   Fibertech's Tariff offerings at 1-3, PP 2-5. The Tariffs attached to the
   Fibertech Nov. 30 Letter  include Fiber Technologies Networks, L.L.C.,
   Reseller of Interexchange Toll Services Tariff, PA P.U.C. No. 1, Effective
   June 19, 2002 ("IXC Reseller Tariff"); Fiber Technologies Networks,
   L.L.C., Competitive Access Tariff, Supplement No. 4 to PA P.U.C. No. 3,
   Effective September 30, 2005 (revising PA P.U.C. No. 3, Effective June 19,
   2002) ("CAP Tariff"); Fiber Technologies Networks, L.L.C.,
   Facilities-Based Interexchange Toll Services Tariff, Supplement No. 1 to
   PA P.U.C. No. 4, Effective September 30, 2005 (revising PA P.U.C. No. 4,
   Effective June 19, 2002) ("IXC Tariff"); and Fiber Technologies Networks,
   L.L.C., Switched Access Service for Connection to Communications
   Facilities Tariff, PA P.U.C. No. 5, Effective June 19, 2002 ("Switched
   Access Tariff"). See Complainant's Reply File No. EB-05-MD-014 (filed Aug.
   30, 2005) ("Reply") at 9-10; Letter dated October 6, 2005 from J.D. Thomas
   and Genevieve Sapir, to Marlene Dortch, Federal Communications Commission,
   Office of the Secretary, File No. EB-05-MD-014 at 1, attaching Declaration
   of James Baase, Vice President, Engineering, of Fibertech Networks, LLC,
   at 1, P 2.

   See, e.g., Complaint at 1, P 3; Response at 2, P 3.

   47 U.S.C. S 224(f)(1) (emphasis added). See 47 U.S.C. SS 224(a)(4)
   (defining "pole attachment" as "any attachment by a cable television
   system or provider of telecommunications service to a pole, duct, conduit,
   or right-of-way owned or controlled by a utility"). See also National
   Cable & Telecommunications Ass'n, Inc. v. Gulf Power Co., 534 U.S. 327
   (2002) ("NCTA v. Gulf Power").

   47 U.S.C. S 224(f)(2).

   Complaint at 3, P 10; Exhibit 1, Letter dated April 11, 2005 from Julie S.
   Adams, Director of Regulatory Affairs and Compliance, Fibertech to Mr.
   Kevin Albaugh, Vice President Regulatory Affairs, NPTC ("Fibertech April
   11 Letter") and Exhibit 3, Letter dated May 5, 2005 from Charles B.
   Stockdale, Vice President and Corporate Counsel, Fibertech to Mr. Kevin
   Albaugh, Vice President Regulatory Affairs, NPTC ("Fibertech May 5
   Letter") at 1; Response at 4, P 10.

   Fibertech May 5 Letter at 1. See Fibertech April 11 Letter at 1.

   Fibertech April 11 Letter at 1; Fibertech May 5 Letter at 1.

   Complaint at 3, P 11 and 4, P 13; Exhibit 2, Letter dated May 4, 2005 from
   Kevin J. Albaugh, Vice President Regulatory Affairs, NPTC, to Julie S.
   Adams, Director of Regulatory Affairs and Compliance, Fibertech ("NPTC May
   4 Letter") (seeking additional information about Fibertech's attachment
   request); Exhibit 4, Letter dated May 25, 2005 from John A. Alzamora,
   Counsel to NPTC to Charles B. Stockdale, Vice President and General
   Counsel, Fibertech ("NPTC May 25 Letter") at 1-4 (denying attachment
   request); Response at 4-5, P 11.

   NPTC May 4 Letter at 1; NPTC May 25 Letter at 1-4.

   See, e.g., Complaint at 8-9, P 34. Specifically, Fibertech seeks an order,
   inter alia, requiring NPTC to: (1) immediately commence survey and
   engineering work on the poles in NPTC's service area to which Fibertech
   seeks to attach; (2) immediately commence good-faith negotiations for a
   pole attachment agreement, with a commitment to execute a new pole
   attachment agreement no later than 30 days from the date of such order;
   (3) grant access to NPTC's poles without a formal agreement in the event
   NPTC fails to complete a just and reasonable pole attachment agreement
   within the 30-day time period; and (4) commence make-ready/facilities
   arrangements no later than 15 days from the date of such order. Complaint
   at 9, P 34.

   47 U.S.C. S 224(f)(1).

   47 U.S.C. S 153(44) (emphases added).

   47 U.S.C. S 153(46) (emphasis added).

   47 U.S.C. S 153(43).

   Virgin Islands Tel. Co. v. FCC, 198 F.3d 921, 927-30 (D.C. Cir. 1999)
   ("Vitelco") (emphasis added) (affirming AT&T Submarine Sys., Inc.,
   Memorandum Opinion and Order, 13 FCC Rcd 21585 (1998)).

   Vitelco, 198 F.3d at 924-27. See, e.g., Cable & W ireless plc, Memorandum
   Opinion and Order, 12 FCC Rcd 8516, 8521-23, PP 12-17 (1997);
   Federal-State Joint Board on Universal Service, Report and Order, 12 FCC
   Rcd 8776, 9177-78, P 785 (1997) (subsequent history omitted) ("Universal
   Service Order"). The Act defines "common carrier" or "carrier" as "any
   person engaged as a common carrier for hire, in interstate or foreign
   communication by wire or radio ...." 47 U.S.C. S 153(10).

   Southwestern Bell Telephone Co. v. FCC, 19 F.3d 1475, 1480 (D.C. Cir.
   1994) (quoting National Ass'n of Regulatory Util. Comm'rs v. FCC, 533 F.2d
   601, 608-09 (D.C. Cir. 1976) (internal quotes and footnotes omitted)).
   See, e.g., National Ass'n of Regulatory Util. Comm'rs v. FCC, 525 F.2d 630
   (D.C. Cir. 1976), cert. denied, 425 U.S. 992 (1976).

   See, e.g., Federal-State Joint Board on Universal Service,  Report to
   Congress, 13 FCC Rcd 11501, 11556, P 115 (1998) ("Universal Service Report
   to Congress"); Universal Service Order,  12 FCC Rcd at 9177-78, P 785
   (holding that "[c]ommon carrier services include services offered to other
   carriers, such as exchange access service, which is offered on a common
   carrier basis, but is offered primarily to other carriers"). See generally
   MTS and WATS Market Structure, Phase I, Third Report and Order, 93 FCC 2d
   241, 246-47, 249-50, PP 13-14, 23 (1983) ("MTS/WATS Market Structure
   Order") (stating that access charges are regulated services and include
   "carrier's carrier" services).

   47 C.F.R. S 1.1409(b).

   47 C.F.R. S 1.1409(b).

   Certificate A-311101 and Certificate A-311101 F0003, attached to Fibertech
   October 25 Letter; Certificate A-311101 F0004, attached to Fibertech Aug.
   15 Letter.

   IXC Reseller Tariff; CAP Tariff; IXC Tariff; Switched Access Tariff,
   attached to Fibertech October 25 Letter; Complaint at 3, P 10; Fibertech
   April 11 Letter at 1; Fibertech Nov. 30 Letter attaching Fibertech's PaPUC
   Tariffs.

   See Letter dated December 15, 2005 from John Alzamora, Counsel for NPTC,
   to Barbara Esbin, Market Disputes Resolution Division, Enforcement Bureau,
   File No. EB-05-MD-014 ("NPTC Dec. 15 Letter") at 4-6 (citing 66 P.C.S.A. S
   3012).

   66 P.C.S.A. S 3012. Compare with 47 U.S.C. SS 153(44) (defining
   "telecommunications carrier," in pertinent part, as "any provider of
   telecommunications services ... ") and 153(46) (defining
   "telecommunications service" as "the offering of telecommunications for a
   fee directly to the public, or to such classes of users as to be
   effectively available directly to the public, regardless of facilities
   used").

   See NPTC Dec. 15 Letter at 4-6 (citing 66 P.C.S.A. S 102). See also 66
   P.C.S.A. SS 1101, 1102.

   See 66 P.C.S.A. S 102.

   NPTC Dec. 15 Letter at 4-5.

   We leave open the possibility that a state may define either
   "telecommunications carrier" or "telecommunications service" in a manner
   flatly inconsistent with the definitions contained in the Act, such that
   an entity could obtain state certification and file state tariffs, yet not
   meet the definitions contained in sections 153(44) and 153(46) of the Act.
   Similarly, there may be instances where an entity could be certificated to
   provide telecommunications services only in some, but not all, portions of
   a state, such that additional evidence of its status would be required to
   demonstrate a right of attachment in those non-certificated portions of
   the state. Neither situation, however, is presented here.

   Paragon Cable Television Inc. v. FCC,  822 F.2d 152, 153-54 (D.C. Cir.
   1987) (holding that the Commission properly refused to address the
   attacher's arguments challenging the legality of the franchise authority's
   decision to revoke the attacher's franchise, noting that it was
   appropriate for the Commission to employ a "presumption of validity with
   respect to the franchising authority's actions vis-`a-vis the franchise").
   See id. at 154 & n.2 (citing Tele-Communications, Inc. v. South Carolina
   Elec. & Gas Co., File No. PA-83-0027 (Com. Car. Bur. Apr. 19, 1985) as
   holding that the utility could not substitute its judgment for the
   franchising authority by removing pole attachments before such time as the
   franchising authority's revocation actually took effect).

   Texas Util. Elec. Co v. FCC, 997 F.2d 925, 934-35 (D.C. Cir. 1993).

   Moreover, NPTC has adequate recourse at the state level if it believes the
   PaPUC erred either in issuing Fibertech its Certificates, or in accepting
   Fibertech's various Tariffs for filing. See Fibertech Oct. 25 Letter,
   attaching PaPUC Fibertech Order at 3  ("The Applicant complied with
   Section 5.14 of our regulations, 52 Pa. Code S 5.14, relating to
   applications requiring notice. No Protests were filed and no hearings were
   held."); 52 Pa. Code S 54.36 (procedure for protests to applications); 52
   Pa. Code S 5.572 (procedures for petitions for relief following a final
   decision).

   47 C.F.R. S 1.1409(b).

   See, e.g., Response at 1-2, 4-5, 6-8, 11-13, PP 2, 11, 13, 16, 17, 36,
   38-40; NPTC Dec. 15 Letter at 2, 7-8; NPTC May 25 Letter at 1-4.

   Response at 12-13, P 39; NPTC Dec. 15 Letter at 2.

   See Response at 7, P 17; 12-13, PP 39-40; NPTC May 25 Letter at 3; NPTC
   Dec. 15 Letter at 1-2; 7-8.

   47 U.S.C. SS 153(44) and (46) (emphases supplied).

   In addition, such a holding would be inconsistent with the Commission's
   policy of encouraging competition and infrastructure investment and
   deployment in broadband markets. See, e.g., Review of the Section 251
   Unbundling Obligations of Incumbent Local Exchange Carriers, Order on
   Reconsideration, 19 FCC Rcd 20293 (2004); Appropriate Framework for
   Broadband Access to the Internet Over Wireline Facilities, Universal
   Service Obligations of Broadband Providers, Review of Regulatory
   Requirements for Incumbent LEC Broadband Telecommunications Services,
   Computer III Further Remand Proceedings: Bell Operating Company Provision
   of Enhanced Services; 1998 Biennial Regulatory Review - Review of Computer
   III and ONA Safeguards and Requirements, Conditional Petition of the
   Verizon Telephone Companies for Forbearance Under 47 U.S.C. S 160(c) with
   Regard to Broadband Services Provided Via Fiber to the Premises; Petition
   of the Verizon Telephone Companies for Declaratory Ruling, or,
   Alternatively, for Interim Waiver with Regard to Broadband Services
   Provided Via Fiber to the Premises, Report and Order and Notice of
   Proposed Rulemaking, 20 FCC Rcd 14853 (2005) ("Wireline Broadband Order"),
   appeal pending sub nom. Time Warner Telecom v. FCC, No. 05-4769 (and
   consolidated cases) (3^rd Cir. filed Oct. 26, 2005).

   As noted above, these telecommunications services include, for example,
   switched and dedicated long distance services for business customers;
   competitive access services, such as trunk-side transport termination, and
   local transport; and interLATA and intraLATA switched long-distance
   service. See  Section II P 3  supra. We also reject NPTC's further
   suggestion that providers of competitive access services do not qualify as
   telecommunications carriers with pole attachment rights under section 224.
   See Response at 13, P 40; NPTC May 25 Letter at 3 (arguing that
   "Fibertech's purpose in attaching to NPTC poles is not to act as a CLEC or
   an IXC," and suggesting that only CLECs and IXCs have pole attachment
   rights).  NPTC's premise is clearly erroneous, as competitive access
   services are, in fact, "telecommunications services" under the Act. See,
   e.g., 47 U.S.C. S 153(16) (defining "exchange access" as "the offering of
   access to telephone exchange services or facilities for the purpose of the
   origination or termination of telephone toll services."); Tariff Filing
   Requirements for Nondominant Common Carriers, Memorandum Opinion and
   Order, 8 FCC Rcd 6752, 6754, P 13 (1993), vacated on other grounds,
   Southwestern Bell Corp. v. FCC, 43 F.3d 1515 (D.C. Cir. 1995) (recognizing
   that "CAPs are nondominant carriers [i.e., common carriers] because they
   have not been previously declared dominant").

   See, e.g., Integrated Services Digital Networks, First Report, 98 FCC 2d
   249, 278, n.77 (1984) ("A tariff for interstate service is a public offer
   to provide service ... ."); Harry Newton, Newton's Telecom Dictionary 888
   (22nd ed. 2006) (defining "tariff" in relevant part as a "public document
   [that] details services, equipment and pricing offered by the telephone
   company (a common carrier) to all potential customers") (emphasis added).

   See CAP Tariff Section 1, 3^rd Revised page 1; Switched Access Tariff,
   Original Title Page. Similar language describing the carrier's undertaking
   to offer service in accordance with the terms of its tariffs is contained
   in Fibertech's IXC Tariff at Section 2.1.1, Original page 1, and its IXC
   Reseller Tariff at Section 2.1.1, Original page 1.

   See Response at 13, P 40; NPTC May 25 Letter at 1-4.

   Fibertech May 5 Letter at 1.

   Chiaino Declaration at 2, PP 2-3.

   See, e.g., NPTC May 25 Letter at 1-4; Response at 6-8, 12-13 PP 13, 16-17,
   40; NPTC Dec. 15 Letter at 1, 7-8.

   See, e.g., NPTC May 25 Letter at 1-4; Response at 6-8, 12-13 PP 13, 16-17,
   40; NPTC Dec. 15 Letter at 1, 7-8.

   NCTA v. Gulf Power, supra note 13.

   Id. at 333. See generally Heritage Cablevision Assocs. of Dallas. L.P. v.
   Texas Util. Elec. Co, Memorandum Opinion & Order,  6 FCC Rcd 7099, 7104 P
   23 (1991), recon. dismissed, 7 FCC Rcd 4192 (1992), aff'd sub nom. Texas
   Util. Elec. Co. v. FCC, 997 F.2d 925 (D.C. Cir. 1993) (holding that cable
   system does not lose its pole attachment rights when its attachments are
   used to provide video and non-video services on a commingled basis).

   NPTC May 25 Letter at 3, (citing Deployment of Wireline Services Offering
   Advanced Telecommunications Capability, Order on Remand, 15 FCC Rcd 385,
   401, P 34 (1999) and In the Matter of Federal-State Joint Board on
   Universal Service,  Report to Congress, 13 FCC Rcd 11501,  11512-14, PP
   23-27 (1998) ("Universal Service Report")); See Response at 12, P 38.

   Response at 7, P 16; NPTC May 25 Letter at 3. The Act defines "information
   service" as "the offering of a capability for generating, acquiring,
   storing, transforming, processing, retrieving, utilizing, or making
   available information via telecommunications, and includes electronic
   publishing, but does not include any use of any such capability for the
   management, control, or operation of a telecommunications system or the
   management of a telecommunications service." 47 U.S.C. S 153(20).

   Inquiry Concerning High-Speed Access to the Internet Over Cable and Other
   Facilities, Internet Over Cable Declaratory Ruling, Appropriate Regulatory
   Treatment for Broadband Access to the Internet Over Cable Facilities,
   Declaratory Ruling and Notice of Proposed Rulemaking, 17 FCC Rcd 4798,
   4821-23, PP 36-38 (2002) ("Cable Modem Declaratory Ruling"); Wireline
   Broadband Order, 20 FCC Rcd at 14863-64, PP 14-15.

   See, e.g., National Cable & Telecommunications Ass'n v. Brand X Internet
   Services, 545 U.S. 967, 125 S.Ct. 2688, 2702-12 (2005) ("Brand X")
   (affirming Cable Modem Declaratory Ruling); Wireline Broadband Order, 20
   FCC Rcd at 14863-64, PP 14-15; Cable Modem Declaratory Ruling, 17 FCC Rcd
   at 4821-22, PP 36-38; Universal Service Report to Congress, 13 FCC Rcd at
   11537-40, PP 76-78.

   Wireline Broadband Order, 20 FCC Rcd at 14910-11, P 104.

   See Wireline Broadband Order, 20 FCC Rcd at 14901, 14909-10, PP 90, 103;
   Cable Modem Declaratory Ruling, 17 FCC Rcd at 4822-25, PP 38, 41-43;
   Universal Service Report to Congress, 13 FCC Rcd at 11520-21, PP 39-41.

   See Wireline Broadband Order, 20 FCC Rcd at 14909-10, P 103.

   See Cable Modem Declaratory Ruling, 17 FCC Rcd at 4821, P 35; Universal
   Service Report to Congress, 13 FCC Rcd at 11530, P 59 (noting "Congress's
   direction that the classification of a provider should not depend on the
   type of facilities used . . . [but] rather on the nature of the service
   being offered to customers").

   See, e.g., CAP Tariff at Section 3.4, 1^st Revised Page 14, Original Page
   15, 1^st Revised Page 16 (offering "Dedicated High-Speed Digital Service"
   configured as a "point-to-point service" connecting two
   customer-designated premises at varying speeds, including DS-3, OC-3,
   OC-12, OC-48, OC-192 services); Switched Access Tariff at Section 3.1
   (offering "a two-point communications path between a Customer's premises
   (or a collocated interconnection location) and [Fibertech's] network").

   Wireline Broadband Order, 20 FCC Rcd at 14910, P 103.

   Response at 13-14, PP 41-45.

   Letter Ruling dated July 6, 2005 from Alexander P. Starr, Chief, Market
   Disputes Resolution Division, Enforcement Bureau, to J.D. Thomas,
   Genevieve D. Sapir, Counsel for Complainant, and John A. Alzamora, Counsel
   for Respondent, File No. EB-05-MD-012 at 2, (citing 47 C.F.R. S 1.1404(m)
   & (l)).

   See Letter Ruling dated November 15, 2005 from Barbara Esbin, Market
   Disputes Resolution Division, Enforcement Bureau, to J.D. Thomas,
   Genevieve D. Sapir, Counsel for Complainant, and Kenneth E. Hardman and
   John A. Alzamora, Counsel for Respondent, File No. EB-05-MD-014 (directing
   both parties to provide additional briefing of certain legal issues;
   directing Fibertech to provide all tariff filings referenced in the
   Complaint; and granting Fibertech's request to file a declaration in
   support of its Reply, its four Certificates, and the PaPUC Fibertech
   Order).

   The relief granted extends to all poles, ducts, conduits and rights-of-way
   over which NPTC is responsible for acting on third-party requests for
   access, including facilities NTPC manages or controls under joint use or
   sharing agreements. See Complaint at 8-9, P 34.

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   Federal Communications Commission DA 07-486

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   Federal Communications Commission DA 07-486