FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28 - April 08, 2011 Page: 5,251
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timeline offers certainty to attachers and allows them to make concrete business plans.66 Beyond
generalized problems caused by utility lack of timeliness from initial request through completion,67 the
record showspervasive and widespread problems of delays in survey work,6" delays in make-ready
performance, delays caused by a lack of coordination of existing attachers,70 and other issues.71
Adopting a specific timeline will also generate jobs and help to move large broadband projects forward
more expeditiously, including those providing broadband to schools under the E-rate program.72
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network deployment significantly delayed by failure to timely attach to poles); Letter from Clifford K. Williams,
Director-Regulatory & Compliance, Sidera Networks, LLC, to Marlene H. Dortch, Secretary, FCC, WC Docket
No. 07-245, RM-11303, RM-1293, at 1-2 (filed Mar. 1 1, 2011) (Sidera Mar. 1 , 2011 Ex Parte Letter) (citing
delays of up to 2 years); Letter from Brian Regan, Director, Government Relations, PCIA, to Marlene H. Dortch,
Secretary, FCC, WC Docket No. 07-245, GN Docket No. 09-51, at 3-4 (filed Mar. 2, 2011) (PCIA Mar. 15 Ex Porte
Letter) (describing specific obstacles, including delays, faced by wireless providers); Letter from Jennie P. Chandra,
Senior Counsel, Windstream to Marlene H. Dortch, Secretary, FCC, WC Docket No. 07-245 at 1 (filed Mar. 31,
2011) (Windstream Mar. 31, 2011 Ex Parte Letter) ("One of the greatest challenges Windstream has faced in
deploying fiber is the lengthy, unpredictable, and costly make-ready process. It is not uncommon for a fiber
deployment project to be delayed by one or two years simply because of make-ready issues."). Unless otherwise
noted, all comments are in response to the Further Notice. A list of commenters is provided in Appendix C.
66 See, e.g., Alpheus and 360networks NPRM Comments at 2 (arguing that unknown make-ready intervals make it
extremely difficult to introduce services or promise timely delivery on potential sales); Cavalier NPRMComments
at 6 (arguing for predictability with regard to make-ready because potential customers will not engage a service
without knowing whether it will begin receiving the service in months or in years).
67 See, e.g., TWTC NPRMComments at 15 ("Pole owners often wait months or even years after receiving an initial
application to complete make-ready work, and these delays are exacerbated by the pole owners' refusal to permit a
mutually agreed upon third party to perform the make ready work."); Cavalier NPRM Comments at 6 (stating that
some utilities provide Cavalier access within three months after receiving an application, but others take more than
five times as long); Alpheus NPRMComments at 2 (complaining that the length of time for completion of make-
ready varies significantly); Letter from Jean L. Kiddoo, counsel to MetroPCS Communications, Inc., to Marlene H.
Dortch, Secretary, FCC, WC Docket No. 07-245, at 3 (filed Mar. 30, 2011) (stating that a significant hurdle with the
issue of delay is that "most pole owners reject the notion of having any timeline in any circumstance").
68 See, e.g., Comments of Indiana Fiber Works, RM-11303 (filed Jan. 30, 2006) (noting that it has experienced
serious delays involving its applications to one of the principal pole owners in its service area, often exceeding 45
days); Sigecom Comments, RM-11303, at 4 (filed Jan. 27, 2006) (citing mediation on delayed pre-construction
survey to confirm Fibertech's allegation that pole owners frequently do not meet the 45-day time frame set forth in
the Commission's rules).
69 See, e.g., PCIA Mar. 2, 2011 Ex Parte Letter at 4 (reporting that after months of negotiation, one utility provided a
distributed antenna system (DAS) provider with make-ready estimation of 260 days for the installation of 20 DAS
nodes); id. at 4 (reporting that Windstream has refused to agree to make-ready timelines for wireline and wireless
attachments, as has Frontier in Minnesota); Crown Castle NPRM Comments at 7 (asserting that make-ready work
can take up to a year to complete when completed by the pole owner's internal personnel, often because of difficulty
in scheduling of crews in the field); Montgomery and Anne Arundel Counties Reply at 4 (asserting that recent
experience with broadband deployments requiring pole attachments has been that the make-ready work performed
by utility pole owners typically takes up to a year to complete, can take up to eighteen months in many cases, and is
especially slow for larger deployments).
70 See, e.g., Sidera Mar. I I, 2011 Ex Parte Letter at 4.
71 Current Group NPRM Comments at 3 (complaining that utilities often seek to delay potential competitors' market
entry by forcing them to engage in disputes over well-settled issues).
72 FiberLight Feb. 23, 2011 Ex Parte Letter at 2 ("With a pole attachment timeline in place consistent with that
proposed by the Commission, FiberLight would be able to provide between 4-5 times as many construction projects
thus creating more jobs and serving more areas."); Windstream Mar. 31, 2011 Ex Parte Letter at 3 ("Time and
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United States. Federal Communications Commission. FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28 - April 08, 2011, book, April 2011; Washington D.C.. (digital.library.unt.edu/ark:/67531/metadc52169/m1/423/: accessed October 18, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.