Verizon is taking the position that the one-touch-make-ready (OTMR) process for new pole attachments should apply to what are deemed “simple” or “complex” make-ready processes, in contrast to AT&T's position.
In an FCC filing (PDF), Verizon said that OTMR can apply to various make-ready situations, giving pole owners and present attachers the option to extend the review process before any work is done.
By adopting rules that would permit new attachers the option of using an OTMR process, the FCC could help the overall wireline and wireless industry segments accelerate fiber and small-cell deployments.
“We have explained that OTMR is appropriate for both simple and complex make-ready, perhaps with a longer period for review and consultation with existing attachers before OTMR begins for complex work,” Verizon said in its filing. “Similarly, the Commission should not adopt the BDAC’s [Broadband Development Advisory Committee’s] conclusion that every attachment outside of the communications space is beyond the scope of OTMR.”
To make its case, Verizon cited a finding by Corning, which said in an FCC filing (PDF) that the benefits of OTMR over a five-year period would facilitate broad expansion of FTTP and 5G rollouts.
The fiber manufacturer said that OTMR would drive an additional $12.6 billion in enabled capex investment for FTTP and an additional $8.8 billion in enabled capex for 5G fixed wireless. Additionally, an OTMR policy would drive 8.3 million incremental premises passed by fiber and 5.9 million incremental premises passed by 5G fixed wireless.
A CMA Strategy Consulting report (PDF) commissioned by Corning said that “allowing OTMR has the potential to enable wider deployment of next generation fiber and wireless networks in many areas of the country” and that “higher costs/fees on next generation wireless network operators could significantly decrease investment in and further deployment of such networks.”
One of the sticking points for Verizon and fellow telco AT&T related to OTMR is the potential for a new attacher’s contractor causing damage and service outages for local businesses as well as public safety and government entities.
Verizon claims that its OTMR approach would give existing attachers notice of all OTMR activity taking place on a pole.
“[A]ny concerns about minimizing the impact of an outage can be remedied by requiring the new attacher and its contractor to coordinate with the existing attacher regarding the scheduling and duration of an outage, if one is necessary,” Verizon said. “Such coordination would allow the existing attacher to reroute traffic, inform customers, or take other steps to reduce the impact of an outage.”
Not everyone has the same view Verizon has about OTMR.
Fellow ILEC AT&T asked the FCC to consider a new OTMR rule that would limit the process to routine transfers on existing utility poles. In a January FCC filing (PDF), AT&T said that applying this concept would reduce the possibility that existing services would be interrupted during the OTMR process.
“Limiting OTMR to routine transfer would minimize service disruptions, which are inherent in complex make-ready work such as transfers of wireless equipment and cable splicing,” AT&T said in its filing.
AT&T contends that any outage could also compromise local and national public safety organizations like fire and police departments as well as consumers. The telco added that an existing pole attacher has more experience in handling or finding ways to avoid potential outages in a community.
Avoiding deployment delays
Verizon said that while some have raised the notion that most make-ready is simple, there’s no material benefit to extend OTMR to complex make-ready, as any delayed access to even one pole could hold up the completion of a broader network expansion project.
“Some parties also argue that because most make-ready is simple make-ready, there’s little benefit in extending OTMR to complex make-ready,” Verizon said. “But, as INCOMPAS has noted, sometimes delayed access to a single pole can delay an entire project.”
The telco suggested that instead of excluding complex make-ready from OTMR, the FCC should require that existing attachers be provided with a “slightly longer” notice period before a contractor conducts complex OTMR.
“To the extent that the Commission’s OTMR rules draw a distinction between simple and complex work, clear, objective criteria are necessary to minimize disputes,” Verizon said. “We agree with the BDAC that a reasonable definition of 'complex' make-ready is work that is 'reasonably likely to cause a service outage(s) or facility damage,' and splicing or activities that involve relocating existing wireless antennas could be included as examples of complex work.
But understanding whether OTMR is either “simple” or “complex” is just one element of the broader OTMR process. Following the BDAC’s proposal, an attacher’s contractor should also be able to figure out whether the make-ready work is either simple or complex while offering a pole owner the right to object if they don’t meet certain safety and reliability criteria.
During this process, Verizon suggested that the FCC “should reject calls for existing attachers to make this determination because existing attachers may have incentives to over-designate work as complex in order to slow the new attacher’s deployment.”