PCIA Urges FCC to Amend Rules


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PCIA—The Wireless Infrastructure Association and its HetNet Forum submitted comments to the FCC in support of the Petition for Reconsideration or Clarification jointly filed by the National Cable and Telecommunications Association, COMPTEL, and tw telecom inc. regarding pole attachment rules. PCIA’s comments urge the Commission to “clarify or amend its rules to eliminate certain anomalies in the ‘telecom’ attachment rate that may result when the actual number of attaching entities on a pole differs from the number of attaching entities presumed under the Commission’s pole attachment rules,” the statement reads. “The importance of the Commission’s pole attachment rules to PCIA’s membership is a matter of public record. For example, since adoption of the Commission’s 2011 Report and Order and Order on Reconsideration in WC Docket No. 07-245 (“Pole Attachment Order”), DAS providers have observed increased efficiencies in the pole attachment process, including lower, more equitable attachment rates, increased use of pole tops, and improved predictability in the design and implementation of DAS.  The Pole Attachment Order also has proven to be a critical tool for PCIA’s members when working with the minority of utilities who have historically been reluctant to provide pole access to wireless service providers.  Although all of the difficulties with the pole attachment process have not been resolved, the Pole Attachment Order has helped to facilitate dispute resolution and promote more rapid deployment of new wireless services. To eliminate the anomalies discussed in the Petition, the Commission can and should modify its pole attachment rate formula. Such action will serve the public interest by providing attaching entities and pole owners with greater rate certainty, thereby minimizing the potential for disputes where use of Section 1.417(c)’s presumptive number of attachers results in an unintended disparity between the telecom attachment rate and the cable attachment rate. PCIA looks forward to reviewing the refreshed record submitted in response to the Public Notice, but in the interim the proposed rule clarifications or amendments suggested by the Petitioners are a good starting point for further discussion.  In all cases, however, the Commission should make clear that the benefits of any rule clarification or amendment adopted in response to the Petition will be equally available to both wireline and wireless telecommunications providers.”

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