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Key Components of Joint Use

This list of items found here is part of a larger, strategic approach to operational excellence from the team at PPL Corporation. PPL is an industry-leading utility with a family of companies in our region. Philip Woodward and Darryl Preziosi developed this eight-item list and have often referenced it to help our team and their fellow utilities better understand telecom attachments and all that these programs entail. Below is my attempt to unpack the importance of these items and clarify how excellence in these categories can lead to a thriving joint use program.

Pole Attachments

It's an interesting time in the world of telecom attachments. There's a crazy amount of money going into broadband deployment, we're starting to focus on communities that typically get ignored, and the FCC is requiring nutrition labels for internet services.

While this broadband activity is exciting and encouraging, it still represents an additional strain on our electrical distribution grid—both in terms of safety and reliability. As more engineering and construction occur, it becomes exponentially more difficult to ensure that communication workers can operate safely and that every pole worked on is left in compliance with modern standards.

The attachments aren't all going on empty poles (the one-touch make ready dream), and with so many providers rushing to be the first to serve a new region, there are often simultaneous ongoing attachment requests from multiple providers.

It's a lot to get right, and pressure is building. Managing this with excellence is hugely important and in the spotlight more than ever before.

But that's not all...

The considerations of a healthy joint use/pole attachments program are typically focused on the hot-button issues that represent current public interests. We've talked a lot about how the attachment requests are submitted, what the timelines are, and how permitting and construction occur in different US markets.

This is not the whole picture. Pole owners have more to manage, and these considerations are important for the following parties:

The telecom attaching companies and their contractors
The governing bodies/regulatory committees
Vendors performing related work
Broadband consumers (our families, businesses, and communities)
Local government

Here's a list that we reference to make sure we're looking at the bigger picture when developing products and services.

1. Regulations

This set of considerations has to do with the relevant governing bodies for both utilities and the telecom process. A primary concern is the FCC/PUC timelines for the pole attachments process to make sure requests are processed, engineered, and released in a timely manner.

There is ongoing effort from the FCC to adapt pole access rules and require different timelines and protocols for the attachments process. Generally, these efforts seek to improve broadband deployment build times without causing harm.

2. Codes, Specifications, and Standards

The National Electric Safety Code (NESC), combined with each pole owner's construction/safety standards, is a powerful one-two punch that keeps us safe and protects the reliability of our electrical grid. These continue to evolve as the years go by and must be maintained as fiber is built to thousands of poles across a pole owner's footprint each year.

Additionally, pole owners must comply with state and municipal requirements which may vary drastically throughout their service territory.

Note: California uses GO95 standards to administer state-wide safety requirements for utility poles and their attachments.

3. Pole Attachment License Agreements

The pole owner is responsible for managing legal contracts with every attacher in their footprint. These agreements specify terms, rental rates, auditing rights, liability, and more. There are different types of agreements for different communication providers (and different types of agreements for ILECs and CLECs), and in some regions, pole owners have Joint Ownership agreements as opposed to just having Joint Use agreements. This makes it tricky to roll out sweeping changes to a program—all agreements must be reviewed, and new agreements may need to be negotiated.

4. Application and Make Ready Process

This is the part most people think of when they think about joint use. It answers the questions: how do communication providers and their contractors submit attachment applications? How does the survey and engineering process work? How is the construction process managed? How is as-built documentation leveraged to ensure safety and adherence to standards?

Pole owners are responsible for managing all incoming applications, communicating how the process works, solving attacher invoicing/vendor payments, fielding questions about hundreds of individual application questions, managing construction, and much more.

5. Attachment Records/Data

It's crucial that attachment records are up-to-date, but not just so that the pole owner can properly invoice rental fees to the providers in their footprint. In the event of a pole strike or other structural issue, the communications facilities on the pole may need critical work so the pole owner can restore power and keep the community safe. When the other entities attached to a pole are unknown, it can cause confusion and delays. Unclear attachment records can also hang up double wood transfers/resolution, relocations, and road-widening projects.

Accurate records are also a critical way to reduce the number of unauthorized attachments in a pole owner's footprint. Unauthorized attachments aren't primarily an issue of unclaimed rental billing—they represent a safety and reliability risk because they didn't go through an approved engineering, design, and construction process. Unsafe attachments put communications workers in harm's way and increase the likelihood of avoidable power outages.

System-wide attachment audits can be performed at regular intervals to correct attachment records, as well as identify unauthorized attachments and make sure they go through either a removal or acceptable engineering process that ensures safety and standards adherence.

6. Rental Billing

Attachers typically pay a per pole or per attachment fee to be attached to utility poles. This invoicing happens at a set interval and requires up-to-date attachment records. Regular attachment audits can help resolve any potential billing disputes.

7. Attachment Transfers/Double Wood Conditions

Have you ever seen this?

Double wood condition caused by in-progress pole transfer
Double wood condition caused by in-progress pole transfer
"Double wood" is a term used to describe the purgatory state from when a new pole is placed up until communication transfers are complete and the stub pole is removed. Double wood is a visual indication that attachment transfers are still in progress. Poles are replaced for safety and reliability purposes, but communication transfers often take months or years. This creates its own safety and reliability risks and generally attracts the attention of neighboring property owners due to its cluttered, unappealing aesthetic.

Double wood conditions also complicate record-keeping because they involve tracking two assets in close proximity in a GIS database. There are several ways to mitigate double wood, such as attachment audits, a robust transfer notifications system, one-touch make ready, and more.

8. Continuous Improvement

When systems stop growing, they start dying. Joint use is no different, and for this reason, advancements to a program's efficiency or effectiveness are essential to both surviving and thriving.
Continually investing in technology, education, communication, and reporting in all of these areas allows pole owners to set new standards of excellence, as well as demonstrate a desire to improve the quality of life and levels of access for communities in their footprint without sacrificing safety or reliability.

While each pole owner and region takes a different approach to the components above, these topics are universal concerns that affect ongoing efforts to bring broadband to all. I hope that communication providers, engineering vendors, software development teams, and local government officials will consider this list and find creative solutions to bring reliable utilities to underserved Americans.
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