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Centurylinktm CenturyLinkTM Pamela Sherwood Hollick Assistant General Counsel 4625 W 86 th Street Suite 500 Indianapolis, IN 46268 Telephone: 317.713.8977 [email protected] January 13, 2020 VIA Email for Electronic Filing: [email protected] Honorable Michelle L. Phillips Secretary New York State Public Service Commission Three Empire State Plaza Albany, New York 12223-1350 Re: Case 16-M-0330 – Initial Comments of CenturyLi nk Communications, LLC, Level 3 Communications, LLC, Broadwing Communications, LLC, WilTel Communications, LLC, Global Crossing Telecommunications, Inc., Global Cr ossing Local Services, Inc., TelCove Operations, LLC, and Level 3 Telecom of New York LL C (the “CenturyLink Operating Companies”) Dear Secretary Phillips: On behalf of the CenturyLink Operating Companies, e nclosed please find the above-referenced Initial Comments for filing with the Commission. Please acknowledge receipt and acceptance of this f iling. Should you have any questions concerning this filing, please do not hesitate to contact the undersigned. Respectfully submitted, Pamela Sherwood Hollick Assistant General Counsel Enc. BEFORE THE STATE OF NEW YORK PUBLIC SERVICE COMMISSION ) Petition of CTIA - The Wireless ) Association to Update and Clarify ) Wireless Pole Attachment Protections ) Case No. 16-M-0330 ) INITIAL COMMENTS OF CENTURYLINK ON WIRELINE POLE ATTACHMENT ISSUES IDENTIFIED IN THE COMMISSION’S NOVEMBER 12, 2019 NOTICE SEEKING COMMENTS On November 12, 2019, the New York Public Service Commission (“Commission”) issued a Notice Seeking Comments in the above referenced docket, which has been expanded to include not only wireless pole attachment protections, but also wireline pole attachment issues. In its Order, the Commission directed further consideration be given to both wireless and wireline attachment policies, including improvements to streamline the make-ready, survey and construction processes. The Commission seeks comments on new technologies and attachment methods, accommodating large-scale projects in a non-business as usual construction environment, the make-ready process, and the feasibility of One-Touch-Make-Ready (OMTR). CenturyLink Communications, LLC, Level 3 Communications, LLC,, Broadwing Communications, LLC, WilTel Communications, LLC, Global Crossing Telecommunications, Inc., Global Crossing Local Services, Inc., TelCove Operations, LLC, and Level 3 Telecom of New York LLC (the “CenturyLink Operating Companies” or “CenturyLink”) submits these initial comments on the some of the key issues impacting CenturyLink, but has not answered all the questions or addressed each issue listed in the Notice Seeking Comments at this time. CenturyLink is both a pole owner (owns approximately 2 million poles nationally) and attaches our facilities to over 5 million poles nationwide. We have been active in pole attachment rulemakings and proceedings in the surrounding states, including filing comments and testifying in Massachusetts, New Hampshire, and Maine. We provided comments to the Connecticut and Vermont Commissions as those states work to reduce delay and facilitate faster broadband deployment. Our perspective on pole attachments, including the time frames for completing make-ready work and the need for processes to streamline attachment, represent our balanced perspective as well as our experience with other pole owners across the nation. CenturyLink Supports Efforts to Streamline Processes and Eliminate Delay It is time to update and clarify the existing Policy Statement on Pole Attachments attached as Appendix A the Order Adopting Policy Statements on Pole Attachments, issued on August 6, 2004 in Case 03-M-0432, which contain provisions addressing the pole attachment process, including make-ready and temporary arrangements. Other reverse preemption states have undertaken efforts to update their rules, often mirroring or incorporating provisions of the FCC’s rules, and in doing so have streamlined make-ready timelines, included explicit rate formulas, set forth additional remedies to deal with delays, such as self-help options. For instance: • The New Hampshire Public Utilities Commission revised its rules to shorten make-ready time frames consistent with the FCC’s process, and mirrored the FCC’s rules that allow attachers to exercise self-help using a preapproved contractor if the make-ready work is not completed timely by the pole owner.1 • The Maine Commission adopted rule revisions that streamlined the make ready process and 1 See NHPUC Docket No. DRM 17-139 - Utility Pole Attachment Rules, finalized August 27, 2018, Reference Doc. #12574, Puc 1300 - Utility Pole Attachment Rules . 2 timelines and set forth a self-help provision to allow an attacher to hire a contractor to complete a survey or the make-ready work if not completed in the required time frames by the pole owner.2 It further revised its Chapter 888 Pole attachment rules to incorporate the FCC’s Cable Rate methodology as the formula for determining a just and reasonable attachment rate. 3 Maine’s rules make clear that a prohibition on boxing or extension arms is presumed unreasonable, with the presumption rebuttal upon clear and convincing evidence that a unique situation would pose an unsafe result. • The Connecticut Public Utilities Regulatory Authority (PURA) has an open docket to address pole attachment issues, including how to eliminate multiple touchpoints, a single pole administrator for joint-pole-owners, use of contractors for self-help, make ready timelines, overlashing, and temporary attachments. 4 Recently, the PURA issued a Proposed Interim Decision addressing processes to mitigate delay in the survey and engineering work phase. 5 • The Vermont Public Utility Commission has finalized its rulemaking implementing make- ready timelines and incorporating the One Touch Make Ready (OTMR) process as a means to facilitate the deployment of broadband networks.6 Those final rules were filed with the Vermont Legislative Committee on Administrative Rules on December 2, 2019 2 See Maine Public Utilities Commission Docket No. 2017-00247, Amendment to Chapter 880 – Attachments to Joint-Use Utility Poles; Determination and Allocation of Costs; Order Amending Rule and Factual and Policy Basis, Issued January 12, 2018. 3 See Maine Public Utilities Commission Docket No. 2019-00203, Rulemaking - Amendments to Chapter 880 – Attachments to Joint-Use Utility Poles, Order Amending, Effective November 23, 2019. 4 See PURA Investigation of Developments in the Third Party Pole Attachment Process, Docket No. 19-01-52. 5 See PURA Docket No. 19-01-52, December 23, 2019 Proposed Interim Decision. 6 See Proposed Rules Filed with Interagency Committee on the Rules, 8/14/2019, Vermont Public Utility Commission 19-0252-Rule, In Re Petition of the Department of Public Service for a Rulemaking to Amend Commission Rule 3.708 of the Commission's Pole Attachment and Make-ready Rules . 3 While the Commission’s Policy Statement provides direction and guidance, many of the provisions lack specificity. CenturyLink recommends the Policy Statement be revised to incorporate streamlined processes as detailed in some of the recent revisions made by surrounding states. Revisions to the processes, timelines and procedures are designed to accelerate broadband deployment and reduce delay in construction of network. The FCC’s rules balance the needs of communications companies to deploy vital network facilities with the needs of utility pole owners, including the need to protect safety of life and the reliability of their own critically important networks. The Pole Attachment Rules should incorporate, by reference, the procedures set out in the FCC rules governing timelines for processing applications, conducting surveys, completing make-ready work and conducting inspections. Joint Pole Process Delays: Particular attention should be given to addressing delays associated with pre-attachment work (survey, reconciliation and make-ready quotes) when the electric and communications pole owners must cooperate to complete the work. CenturyLink has experienced lengthy delays (with applications pending for over a year) when one pole owner completes its survey work, but the other joint owner fails to complete its work. Or the two owners are not able to timely “reconcile” their surveys and make-ready estimates to complete one combined response back to the attacher. The rationale for the delays changed each time we escalated or contacted the joint pole owners, including personnel changes and redundant surveys. Other states, like Connecticut, are looking at the designation of a single pole administrator and other processes to reduce the multiple touch-points that cause delay, such as more specific time frames for each pole owner to complete each step of the process. Alternatively, allowing approved contractors to complete the surveys and make- ready estimates, like that recently proposed in Connecticut, could assist with addressing tag/hand-off between the pole owners. 4 OTMR Provisions: The FCC’s recently enacted One Touch Make Ready provisions strike a balance between pole owners’ concerns regarding the safety and integrity of the poles and the pole attachers who seek to speed the deployment of broadband by building out network which requires attachments to poles. The FCC noted that “many utilities that own poles are not comfortable with their current responsibilities for facilitating attachments in the communications space. By shifting responsibilities from the utility to new attacher to survey
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