The Virginia Cable Telecommunications Association (“VCTA”), by counsel, hereby submits comments to the Board of Housing and Community Development (“BHCD”) on suggested revisions to the BHCD’s proposed new version of the Virginia Uniform Statewide Building Code (“USBC”) as set forth in the April 30, 2018 Virginia Register of Regulations.

I.          Introduction

            Since 1966, the VCTA has served as the trade association for cable television operators in Virginia and their affiliates.  As envisioned by the Telecommunications Act of 1996, cable television operators have entered the telecommunications market (through corporate affiliates) as competitive local exchange carriers (“CLECs”) and have become the principal facilities-based competitors to the incumbent local exchange carriers.

II.        Background

            In February 2017, BHCD published amendments to the USBC, including amendments to 13 VAC 5-63-20.D (regarding exemptions from permits) and 13 VAC 5-63-80.B (regarding permit applications), which were two sections of the USBC of particular interest to communications companies (the VCTA had previously commented on and obtained amendments to those sections in 2003).

            The VCTA offered suggested changes to the new proposed language by Comments filed on May 26, 2017 with BHCD.                                                             

During the summer of 2017, the Department of Housing and Community Development initiated a sub-workgroup to address the issues raised by public comments submitted by the cable and telecommunications industries.

            The communications sub-workgroup included representatives of the cable and telecommunications industries, municipal associations, and representatives from the building and fire inspector communities.

            The sub-workgroup reached a consensus and agreed on revised language of the two sections to update and clarify their provisions, as set forth in Workgroup Proposal No. C-102.3.

III.      Summary and Conclusion

            The VCTA supports the consensus language developed by the communications sub-workgroup, and urges the adoption of these two provisions (13 VAC 5-63-20.D and 13 VAC 5-63-80.B) as part of the USBC.

            The VCTA appreciates the opportunity to submit these comments and to help ensure that the Virginia USBC reflects current communications technology and best practices.

                                                 Respectfully submitted, 

                                                 VIRGINIA CABLE TELECOMMUNICATIONS ASSOCIATION

                                                 By: Cliona Mary Robb, Counsel,  May 30, 2018

Cliona Mary Robb

Christian & Barton, L.L.P.

909 East Main Street

Richmond, Virginia 23219

(804) 697-4109

pbroadbent@cblaw.com

VSB No. 34344