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The Virtuous Cycle

Updated: Apr 4

Normally, you're in trouble if your best hope for innovation is increased regulation.

But this might be an exception.

Pole Attachments

The world of pole attachments is a fascinating place that rests at the critical intersection of our electrical grid and our access to internet.

Utility poles are the primary way that power and communications services arrive at your door. This isn't to say that these utilities are never buried, and I'm certainly not discounting the importance of cell signal—but without overhead distribution (read: poles) to connect underground plant back to the network, it just doesn't work. We still need poles.

We've been attaching communications cables to poles for nearly 200 years, but we're still wrestling with the best ways to do it safely and quickly. In most places in America, it works like this—and this is a gross oversimplification:

  1. A communications provider allocates private or public funds to bring service to a new place.

  2. They plan out their route and identify where they can go underground and where they can go overhead. 

  3. They send someone out to collect data from the field so that they can submit requests to attach.

  4. They submit permits for each pole to the correct pole owners.

  5. The pole owner reviews their submission and puts it through their process, which solves all necessary items like billing, engineering, and construction.

  6. Once the necessary electrical work has been completed, the applicant is responsible for coordinating all other construction work needed to create space for their new attachment.

The Perfect Storm

There are two key issues in this process that are causing headaches:

  • Issue one - Every pole owner has slightly different standards for engineering and construction, which means the permitting process varies drastically from one region to the next. Some pole owners only require locations and pole ID numbers, and others require full engineering (make ready and pole loading analysis). Most of the time, the applicant either over- or under-collects data in the field, so they've either already wasted time and money, or they're about to.

  • Issue two - Existing attachers are incentivized to draw this process out as long as possible. The longer they wait, the better. Why would they spend time and energy helping a competitor get on the pole quickly?

The conditions are now ripe for a vicious cycle.

Applicants are losing calendar days due to misunderstanding the pole owners’ priorities, only to finally get things right and find that their competitors have the power to slow them down even further at the one-yard line.

So some of them cut a corner. Or two.

Maybe they build based on existing guying instead of following the design package. Maybe they build before space has been made on the pole. Maybe they don’t ever submit an application and just continue to build out their network.

At first, applicants who choose to follow the rules are left in the dust by the few bad actors who break them. They start to wonder why the system seems to incentivize bad behavior. System-wide audits are rare enough that most unauthorized attachments go years without being caught.

Maybe this leads more attachers to break the rules. Maybe it doesn’t.

Eventually, and inevitably, something goes wrong. There’s a lawsuit, or unauthorized attachments are discovered and investigated. There’s an outage that could have been prevented.

Someone gets hurt.

At this point, the pole owner must respond with more stringent standards, processes, and proactive defensive action. There’s hesitation now, and trust is eroding quickly. And the cycle continues.

Pole owners are forced to adapt processes to catch bad actors, and those playing by the rules have to adapt, too. Frustration builds, mistakes keep being made, and on and on and on.

But we believe there is a way out.

One-Touch Make Ready

This feels like an important preface: the FCC didn't come up with the concept of one-touch make ready, but they have championed it as a part of reports and orders over the past 5 years.

OTMR describes a new protocol to escape the vicious cycle. It works like this:

  1. Certain types of engineering and construction are Simple and need a streamlined process to expedite the pole attachments process.

  2. Communications providers can approach approved contractors (or bring their own qualified contractor) to perform Simple work on the pole.

  3. The approved contractor ensures that their Simple make ready engineering is performed safely and correctly, and any work requiring Complex make ready will go through the standard process.

  4. Once all the Complex work has been completed, the approved OTMR construction contractor performs all existing attacher moves and the installation of the new attachment—all in one go.

  5. A post-construction inspection is performed to ensure that everything was moved and built according to the engineering design and that no new safety issues were created.

One-touch, when executed skillfully, flips the vicious cycle on its head.

A great OTMR process contributes to a healthy joint use program by building trust between all parties involved:

  • Safety and Reliability - pole owners are able to maintain their engineering and construction standards for all make ready, and still utilize their internal processes for all Complex work. They also review as-built documentation to ensure the construction process was performed to their safety and reliability standards.

  • Full alignment - approved one-touch contractors are hired by attachers but also have a reputation at stake with pole owners. This healthy tension leads to decisions that expedite the attachments process, but never at the expense of safety or grid reliability. Because a misstep could result in their approval being revoked, OTMR contractors are very likely to push back on unsafe pressure or practices.

  • Inaction leads to progress - existing attachers are invited to review the make ready plan and raise flags—but they can no longer bring the attachment process to a halt by dragging their feet. The one-touch make ready process provides attachers with full transparency and a platform to vocalize concerns.

What's Coming

Early versions of one-touch are taking shape in markets across the country with varying success. When complemented by an already healthy joint use program, OTMR is a useful arrow in the quiver, but it still doesn't solve every problem.

The FCC will likely continue to update OTMR expectations as it regulates the pole attachments process. The FCC is also seeking input on how to improve broadband deployment across the nation. Many states self-regulate this process, however, and will be making their own determinations about whether or not OTMR is a valid approach.

As funding continues to flood the market, we'll see how healthy one-touch make ready processes continue to evolve to serve the pole attachments industry and help providers bring reliable utilities to underserved communities across America.

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