Draft Discussisn Points for ETD-P Sim Recipie nt - Cenf?entiai 2. Premier is presuming tn everbuiid their cempetiters? existing ?ber in areas. where it has nd East miie ?ber This mntradicts the reasen to net add ?ber in its service areas making any such stratng out oi scenes 3- ?er the "Rec rents: there appears tn be ne route dwersitv extent for the smaii segment being hem ETQP funds. Since the entire mute is net redundant, and there are no speci?c threats peculiar tn the sectien being built with funds. the second redundant name is wt d! scant Ho Actress 4. Premier is using its private central 0! the physicai layer cannectinns needed to create a fail? functionirq middle mite to: itself an unfair advantage in nmmding services using the BTBP funded netwrk. in P?i?simi lever and logical Layer rests are net predictable er tnnwable these must be WMIM ii casein-case basis for speci?c camps-titers tn prewde fer whim Frentrer itself is car may be campeting . be No notice of bandwidth availability is published fer BTDP routes nr {or the. entire Bi?ii 1 i 5. Far any third party aperatdr to use the BTOP network to provide services In the Unis, it must menace Frantier? existing actual middle rniie network. 65 Prentier is net offering campetitive whole-seine cnmmerciai middle mite services en its mm mm either for the present technniogy or fer its promised RDADM rte-rm Wheieseit service n?erings for middle mile networks are reported as a snecdic line item In NTLA in the nuarterly eme submissions. Whalesate commercial sersnces are either dedicated (in a wavelength dieisinn multipierred envirdnmens icir as indefeasinie rights of" use dedii-?i?d strands df fiber that run between central offices. data centers. and other pointsefupresence that provide multiple-previder peering. No IF layer WW 1. There is new puhiic internet cennectnriw previ-ded it STOP ?ber meet paints that 13in ff" competitive whalesale cir retail semces mm the STOP fiber- There is deportunity fer epen access ESP at the meet mint, Access is cinisr thcnugh a singie private provider. tirade-mite Pram Documentation and SW Cm? 1. BTUP ?ber designs for cennectinns by LCRs dd net pruvide between Central OF?ces nr between Central Of?ces and Chis for must sites. The current LCR designs ceuid reascrnahisr be cnnsidered net with 0MB ?t for purpese standards ignid pia ted} and nut 01? scape due tn excessive fiber cnunts. stranded networks reiared engineering and censtrucsidn casts and restricted functinnaiity far BTDP and Grant purpeses. 2. in the State?s current assessments antier has not prdeided adequate documentazien en the design speci?caticins and nrnrecr casts tn mee: STOP audit requirements and reasonable prnject management practices As re?ected in the LCRs, the CM ?iaer exceed industry standards fer fiber ceunts and de net prnuide free: the CG tn the Chis- Current LEE 5, rnvnices and project decumentatidn are not. adequate STOP audit ccimpi'rance Wum??tt?? and grind prnpect management practices for a preiecr of this see 1.. There are ne facilities that can CALEA access at ms: meet points Page 4 ct!