AT&T has told the FCC that it can help the telecom industry reduce the timelines for make-ready processes by allowing new attachers to use a self-help approach and allowing them to be called project managers.
In a FCC filing (PDF), AT&T said that the self-help process will influence existing attachers to work collaboratively with not only the pole owner, but also new attachers and other utilities that have facilities on a pole.
“If multiple existing attachers fail to move their facilities within the reasonable timeframe, the new attacher could invoke its self-help remedy using a one-touch make-ready process,” AT&T said in a FCC filing. “This date-certain self-help remedy provides an incentive for existing attachers to coordinate with the pole owner, new attacher, and other existing attachers, regardless of whether the new attacher is a competitor.”
This contrasts Google Fiber’s stance. The insurgent FTTH provider said in an earlier FCC filing that completing the make-ready process in a reasonable time is challenging because the process is controlled by existing attachers and coordination among all existing attachers.
“Today’s process requires substantial coordination among all existing attachers in the communications space, as well as with the pole owner, making it extremely difficult to complete communications space makeready within 60 days,” Google said in a FCC filing (PDF). “In addition, incumbent communications attachers have little to no incentive to work cooperatively in that process with new providers who may be their competitors.”
AT&T countered that the self-help approach will solve the timeline problem for new attachers, and naming the new attacher as project manager overseeing the make-ready request will further improve efficiencies.
“The self-help remedy referenced above minimizes the extent of this problem, but the Federal Communications Commission can further improve the make-ready process and minimize the frequency that self-help is needed by explicitly appointing the new attacher as 'project manager' of the make-ready process,” AT&T said. “As 'project manager', the new attacher would coordinate the timing of transfers with all parties to ensure all make-ready identified as necessary by the pole owner is completed as expeditiously as possible.”
The service provider added that by appointing the new attacher as project manager, it allows them to work with the existing attachers to get the make-ready work done. As a result, the project manager could spell out responsibilities for itself and other existing attachers to quell any issues that could cause a delay.
“Naming the new attacher as the project manager removes the pole owner as the middle man and puts the new attacher in the driver’s seat to coordinate all moves,” AT&T said. “If existing attachers fail to cooperate with the new attacher, the new attacher can perform all complex transfers that were not performed within the reasonable timeframe. The Commission has previously acknowledged that pole owners need not actively manage and coordinate make-ready to comply with their access obligations under Section 224(f)(1).”