AT&T has asked the FCC to consider a set of new targeted reforms to the current pole attachment process that will not only speed up broadband deployment cycles but retain service reliability and safety.
One of the biggest issues with the pole attachment process for AT&T and new competitors like Google Fiber is the timeline for the make-ready process that carriers and pole owners take before new entrants can get access to a pole.
In an FCC filing, AT&T said that any changes to the make-ready timelines should focus on reforms that “eliminate unnecessary delays, don’t sacrifice safety or service reliability, and eliminate large order ambiguities.”
For attachers that have large order requests, AT&T suggested that the FCC could bring clarity to the pole attachment process by eliminating the arbitrary 30-day window.
Instead, AT&T suggested the FCC could base “the large and larger order designation on the number of poles the pole owner is processing in a state when an order is received, including the new order, better accounts for workloads and minimizes gamesmanship.”
AT&T added that the FCC could retain the 45-day timeline for application and review and pole survey and 14-day timeline for acceptance.
Further, the regulator could reduce the pole attachment by 29 days with two changes to the estimate and make-ready stages: Fold the 14-day estimate stage into the 45-day review and survey stage and eliminate the 15-day make-ready process for pole owners so the “new attacher can immediately perform make-ready.”
Common sense OTMR approach
While AT&T has ardently protested one touch make-ready (OTMR) proposals made by such cities as Louisville, Kentucky, the service provider said the FCC should adopt a common sense/balanced OTMR approach, with necessary safeguards.
A district court recently dismissed a suit filed by AT&T against Louisville for passing an OTMR ordinance that would effectively accelerate Google Fiber’s entry into the market.
During the pole attachment process, AT&T tells the FCC that OTMR should be limited to routine transfers and not to complex work such as cable splicing or moving wireless equipment.
The service provider also emphasized that any make-ready work should be done by pre-approved contracts by pole owners that inform existing attachers of upcoming work at least 30 days in advance.
Pole inspection is also an issue. AT&T said that after the new facilities are put on poles, the new attacher should be liable for inspection costs and should correct any issue caused by their make-ready work.
Leveraging Section 253
Another way the FCC could speed up the pole attachment process would be to leverage Section 253 of the 1996 Telecom Act.
This section of the act prohibits local governments from denying competitive telecommunications carriers the right to use their rights-of-way.
In order to avoid broadband expansion and deployment delays, AT&T suggests the FCC could “encourage uniform local standards and processes” and “be willing to preempt when providers encounter state and local barriers to deployment.”
Additionally, AT&T said the the FCC should create a streamlined Section 253 complaint procedure. Similar to the pole attachment complaint process, this procedure would include a shot clock designed to “increase predictability & expedite relief.”