FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28 - April 08, 2011 Page: 5,252
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Federal Communications Commission
22. As shown in Tables 1 (for attachments in the communications space) and 2 (for wireless
attachments above the communications space), the timeline features four stages:
* Stage 1: Survey. During the 45-day survey phase, the pole owner conducts an
engineering study to determine whether and where attachment is feasible, and what
make-ready is required. (This period has an additional 15 days for large orders as
* Stage 2: Estimate. The pole owner provides an estimate of the make-ready charges
within 14 days of receiving the results of the engineering survey.
* Stage 3: Attacher Acceptance. The attacher has up to 14 days to approve the
estimate and provide payment.
* Stage 4: Make-Ready. The pole owner must notify any attachers with facilities
already on the pole that make-ready for a new attacher needs to be performed within
60 days (or 105 days in the case of larger orders, as defined below).74 In most cases,
any required make-ready work will be completed within this period, but we provide
for additional time in certain circumstances. For wireless attachments above the
communications space, we adopt a longer make-ready period of 90 days (or 135 days
in the case of larger orders), based on safety considerations and the fact that, at
present, there is less experience with application of timelines to wireless attachments
at the pole top.75 Finally, an owner may take 15 additional days after the make-ready
period runs to complete make-ready itself.
23. For most attachments, the total time from submission of the request through completion of
make-ready should take between 105 and 148 days, depending on how long the parties take to prepare
and accept an estimate.76 Attachers may hire contractors authorized by the utility to complete make-ready
either on the 133rd or 148th day, depending on whether an owner timely notifies the attacher that it
intends to move existing facilities and conduct make-ready if existing attachers have failed to move their
attachments. Although we establish this timeline as a maximum, we recognize that the necessary work
can often proceed more rapidly, especially at the estimate and acceptance stages, or for relatively routine
requests. It would not be reasonable behavior for a utility to take longer to fulfill any requests simply
because a timeline with maximum timeframes is being adopted. Likewise, for large orders, we allow 15
more days for the survey and 45 more days to complete make-ready.
(Continued from previous page)
again, KDL's fiber deployment efforts for schools, like cell towers, have been stalled for many months by delays in
the make-ready phase of its projects.").
73 See infra para. 63.
74 See infra para. 63.
75 See 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 2 (filed Mar. 15, 2011) (PCIA Mar. 15 Ex Parte Letter) (indicating
that Utah's total timeline applicable to wireless attachments for fewer than 300 poles ranges from 165 to 180 days,
and Vermont's total timeline for up to 0.5% of a utility's poles is 180 days); Letter from Brian M. Josef, Assistant
Vice President, Regulatory Affairs, CTIA, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 07-245, GN
Docket No. 09-51, at 4 (filed Mar. 15, 2011) (CTIA Mar. 15 Ex Parte Letter) (noting timelines in Utah and Vermont
and stating that "[m]ore states are progressing in the same direction, taking steps to ensure wireless attachers have
access to poles, and specifically access to the pole top").
76 See supra para. 22 (describing the various stages of the timeline and their respective lengths). For wireless
attachments above the communications space, the relevant end point of the timeline is 178 days rather than 148
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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/m1/424/: accessed July 23, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.