Navigating One-Touch Make-Ready in a World of Accelerated Broadband Buildout

In the summer of 2018, the Federal Communications Commission (FCC) issued a declaratory ruling with the title and objective of “Accelerating Wireline and Wireless Broadband Deployment by Removing Barriers to Infrastructure Investment.”  The report and order addressed many topics meant to help accelerate broadband deployment.  One of the new rulings that has caused the most discussion and potential disruption is the One-Touch Make-Ready (OTMR) process.

Before an internet service provider (or any company) can add a new attachment or line to a utility pole, the existing attachments may need to be moved around so that the pole can be made ready to handle a new attachment or line. This is known as make-ready work.  Based on the new ruling, in a location which has adopted OTMR, companies that own utility poles must agree on one or more certified contractors (i.e., chosen either by the pole owners or local governments).  These construction crews are given permission to move all of the existing attachments on a pole in a single visit rather than sending in a unique crew to move each attachment sequentially.

In theory, OTMR places much greater responsibility on the new attacher and lessens the physical and administrative requirement on pole owners and existing attachers.

Pole Owner Questions and Concerns

Some concerns pole owners have expressed include:

  • Who will perform the OTMR work and will it be performed safely and to both the National Electrical Safety Code (NESC) and pole owner construction standards?  

  • What are the qualifications of the contractor?

  • How will timelines and shot clocks be tracked and managed to avoid missed deadlines, finger-pointing, and overall confusion on who’s doing what?

  • Overall, will I be able to effectively recover my costs and control compliant access to my infrastructure without compromising safety and reliability?

For pole owners, supporting the application process is not a revenue-generating activity.  Pole owners can recover their costs for facilitating new attachment requests and then bill an annual rental rate for maintaining the pole per the FCC rate formulas.  As such, pole owners have traditionally relied on basic tools to manage the request and work tracking process (email notifications with tracking requests, timelines in the form of spreadsheets, etc.).

With the explosive growth in the number of incoming requests to attach, along with the new need to efficiently track, pole owners struggle to track the following:

  • Application types
  • Application status and responsibility
  • Volume and associated deadlines
  • Approvals

The sheer number of application workflows and individual transactions that need to be tracked, multiplied by the volume of poles, could easily overwhelm a pole owner and the tools and processes they have traditionally used for managing new requests.

Points to Consider When Assessing Your Current Processes

For pole owners to effectively deal with all the changes that OTMR will bring, they should consider whether their existing tools and processes are sufficient or in need of improvement:

  • Review Current Joint Use Agreements with Third Parties:  Evaluate how existing procedures will be impacted by the OTMR process and if any conflicts exist with the new FCC guidelines.  This may present a good opportunity to clarify and improve legacy agreements while incorporating the new rules to help streamline the process.  Submitting and reviewing requests should be done in a consistent manner and include all supporting documentation.
  • Evaluate Current Contractors:  Assess how effective your onboarding process is for approving contractors that applicants will use to perform field surveys, pole loading, and make-ready design.  Ensure contractors meet your safety and construction standards. 
  • Application Request Tools:  There are numerous steps in the OTMR process that need to be tracked, approved, and communicated.  Notifications should be sent to all stakeholders.  Determine if your current processes allow for this degree of tracking and communication.
  • Ensuring Appropriate Cost-Recovery:  You should be billing for work you have performed in an accurate and timely manner (power make-ready and post-construction audit) before the cost-recovery period times out.
  • Sharing Pole Information:  Determine the benefits of sharing pole location information with the applicant.  You want to ensure they are selecting poles you own, poles that will support the request, and poles that can easily be matched to your pole database (for easy review of existing permits, pre-existing attachment requests, and replacement poles).

The use of OTMR will require that both the attacher and the pole owner make fundamental changes to the way they work and communicate with each other.  

Without clear procedures being communicated to applicants (and their approved contractors) and visibility among all stakeholders to the application status, the sheer volume of activity has the capacity to overwhelm existing processes.

While the above considerations do not constitute a complete checklist, they should be considered as you review your existing processes to ensure the new OTMR changes can be handled in an efficient, safe, and manageable manner.

To learn more about how Osmose can help navigate the new guidelines and create an ironclad OTMR program, please contact your local Osmose representative.  Not sure who your local Osmose representative is?  Email [email protected] to find out.