20250827Comments_2.pdf

From: Brayman, Elizabeth <[e-mail]>
Sent:Wednesday, August 27, 2025 1:43 PM
To: secretary<[e-mail]>
Subject: RUL-U-25-01 Ziply Fiber Comments on Draft Pole Attachment Rules
Hello,
Attached are Ziply Fiber's comments on the draft pole attachment rules in RUL-U-25-01.
Thankyou,
Elizabeth Brayman, Regulatory& External Affairs Manager
425.879.3612 (m)
[e-mail]
ziplyfiber.com
ziply-

Ziply Fiber •
135 Lake Street South,Suite 155, Kirkland,WA 98033 I
M.[phone] pi
[e-mail]
fiber
August 27, 2025
Sent via electronic mail to [e-mail]
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
Re: Draft Pole Attachment Rules
Commissioners:
Ziply Fiber submits these comments to express significant concerns regarding the Commission's
draft pole attachment rules dated August 20, 2025. As a threshold matter, we are disappointed
that the Commission has not widely publicized this process and engaged with the full spectrum of
stakeholders. Based on the information available, it appears that Commission staff have
developed these rules with a limited group of stakeholders, seemingly centered around a single
energy utility.
The current draft is fundamentally incomplete and, in its current form, is a significant barrier to the
prompt and efficient deployment of advanced data networks in Idaho. It stands in stark contrast to
the robust and well-established framework of the Federal Communications Commission's ("FCC")
rules, which are the result of decades of thoughtful consideration and extensive stakeholder
engagement. The draft fails to incorporate key provisions proven to expedite broadband
infrastructure buildout and creates regulatory uncertainty that will discourage investment.
Advanced Notification Requirements
The draft is deficient in its failure to establish clear and binding advance notification requirements
for new attachers. As detailed in the FCC's June 2025 Fifth Report and Order in WC Docket No.
17-84, advanced notification requirements serve a vital purpose in expediting large-scale
deployments. The FCC's framework facilitates pre-planning and coordination by mandating a
meet-and-confer session between utilities and attaching entities before an application is officially
filed. This proactive approach is crucial for identifying and resolving potential issues early, which
minimizes disputes and prevents delays that would otherwise occur.
The FCC's rules also provide certainty by setting clear timelines and defining the consequences of
non-compliance, such as allowing a utility to treat an incomplete application as the advanced
notice, thereby waiving the relevant timelines. This predictable process is essential for managing
ziplyfiber.com

complex infrastructure projects and ensuring that broadband providers can commit resources with
confidence. The Idaho draft's omission of these critical elements creates a vacuum that could lead
to unnecessary delays and a lack of accountability.
Pole Attachment Timelines
The current draft's pole attachment timelines will hinder, not help, broadband deployment. While
the concept of timelines is sound, the draft's definitions for Regular, Mid-Sized, and Large
Orders—based solely on the number of pole attachment requests (under 100, 100-500, and 501-
1,500, respectively)—are inadequate. This approach fails to account for the varying scale of
different utilities' infrastructure. The FCC's definitions, which use the lesser of a specific pole count
or a percentage of a utility's poles, provide a more flexible and equitable framework that is tailored
to different utility sizes.
Furthermore, the draft introduces an "Application re-review" period of 10-15 business days, an
unnecessary administrative step that adds another layer of delay to the process. It also fails to
differentiate between new attachments and overlashing attachments, a common practice used to
upgrade networks that should not be subject to the full application process. The omission of a
specific timeline for One-Touch Make-Ready (OTMR) applications is another significant oversight
that will impede the streamlined deployment of broadband.
Make-Ready Work and Exceptions
The draft's provisions for make-ready work are a significant point of concern. The "Utility Proposal"
for exceptions to make-ready timelines is overly broad and lacks the clear, objective standards
necessary to prevent it from being used to create significant delays. Allowing a utility to deviate
from deadlines for reasons such as "pole owner capacity to process requests to attach" or
"engineering complexity" is a de facto admission of a lack of resources, a reason that the FCC has
explicitly and rightly excluded as a valid justification for delay.
Most critically, the Idaho draft omits the fundamental "self-help" provisions for surveys, estimates,
and make-ready work. The FCC has implemented these mechanisms to empower new attachers
to proceed with deployment if a utility fails to meet its deadlines. These self-help rules are a
powerful tool that prevents utility inaction from becoming a permanent bottleneck to broadband
deployment. Without them, the timelines set forth in the rules are effectively meaningless and offer
no protection for attaching entities.
Contractor Lists and Enforcement
The draft's lack of a clear process for adding contractors to a utility's approved list will also impede
self-help. The FCC's rules, by contrast, require utilities to respond to requests to add contractors
within 30 days and provide for requests to be deemed approved if there is no response. These
rules are vital for ensuring that attachers can access a sufficient pool of qualified contractors to
perform work when self-help is necessary. The absence of these provisions in the Idaho draft will
limit an attacher's ability to utilize self-help, undermining the intent of expedited deployment.
The proposed $500 fine for unauthorized attachments also raises concerns. While a financial
penalty can be a deterrent, the draft fails to provide context for its application, such as a grace
period or a multi-step enforcement process. The provision allowing pole owners to remove
unauthorized attachments at the attacher's expense also lacks a due process framework, which
could be abused.
ziplyfiber.com

In its current form, the draft document is a step backward for broadband deployment in Idaho. It
ignores established, proven practices from the FCC that are designed to promote efficient and
predictable infrastructure buildout. We urge the Commission to revise the draft to align with or
adopt the FCC's rules on advanced notice, comprehensive pole attachment timelines, self-help
provisions, and contractor list management. Doing so will ensure Idaho's regulatory framework is
a facilitator of, not a barrier to, the critical work of connecting all Idahoans to high-speed
broadband.
Sincerely,
qq4_O___
Jessica Epley
VP - Regulatory & External Affairs
Zlply
ziplyfiber.com

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From:Jacob Miller<[e-mail]>
Sent:Wednesday,August 27, 2025 2:30 PM
To: secretary<[e-mail]>; Stephen Goodson
<[e-mail]>
Cc: [e-mail]; [e-mail]; Craig Stevens
<[e-mail]>; Flores, Katie <Katie.Flo [e-mail]>; Guy Cherp
<[e-mail]>;jennifer—[e-mail]; Kenny Wright
<[e-mail]>; Patrick Caron <Patrick.Caron @cableone.biz>; Russ
Young<[e-mail]>; Schwarz, Brett <[e-mail]>;
Stafford G Strong<[e-mail]>; Ron Williams
<RWi Ilia [e-mail]> Subject: ICBA Written Comments re:Case No. RUL-
U-25-01 —Pole Attachment Rules
Dear Ms. Barrios-Sanchez and Mr. Goodson:
Please find attached written comments regarding Case No. RUL-U-25-01 —Pole
Attachment Rules, submitted on behalf of the Idaho Cable Broadband Association, which
represents Charter Communications, Comcast, Cox Communications, and Cable One,
Inc. (d.b.a. "Sparklight")throughout Idaho.
Thankyou,
Jacob Miller
Lobbyist
C: 208.559.2961
P: 208.388.4076
E:jmiller _ hawleytroxelLcom
hawleytroxell.com
Win f
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J6
IDAHO CABLE BROADBAND ASSOCIATION
August 27, 2025
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Ste 201-A
Boise, ID 83714
Attn: Monica Barrios-Sanchez
Commission Secretary
Email: Secretarykpuc.idaho. og_v
Stephen Goodson
Policy Analyst
Email: Stephen.Goodsonkpuc.idaho.gov
RE: ICBA Written Comments re: Case No. RUL-U-25-01 Pole Attachment Rules
Dear Ms. Barrios-Sanchez and Mr. Goodson:
On behalf of the Idaho Cable Broadband Association ("ICBA"), which represents Charter
Communications, Comcast, Cox Communications, and Cable One, Inc. (d.b.a. "Sparklight")
throughout Idaho, the ICBA submits the following comments regarding the proposed rulemaking
governing pole attachments ("Pole Attachment Rules").
This rulemaking represents a pivotal moment for Idaho's digital future. The Idaho Legislature,
through its passage of House Bill 180a, has made its intent clear: "to promote reliable broadband
and wireless connectivity in Idaho" because "[c]onnectivity is essential to public safety and a
modern economy." The Legislature explicitly found that "[p]ermitting delays have hindered
broadband deployment in the state despite historic investments in broadband" and that H180a is
"intended to reduce delays and increase deployment."
Similarly, the Federal Communications Commission (FCC) has consistently worked to facilitate
the pole attachment process to "promote fast, efficient, and ubiquitous deployment of broadband
facilities." The FCC's recent Fifth Report and Order (WC Docket No. 17-84) recognizes that the
influx of government funding for broadband deployment necessitates a more efficient,
collaborative, and predictable pole attachment regime. The FCC's actions are a direct response to
the reality that outdated processes "have resulted in difficulties and delays in accessing poles."
While Idaho is not subject to all of the FCC rules, the record in the Fifth Report and Order is the
PO Box 2634, Boise, Idaho 83701 [phone]
59382.0001.4898-2765-5267.1

most complete and thorough vetting of this issue nationally and should be used to inform Idaho's
rulemaking process.
It is through this lens of clear legislative intent and federal precedent that we must evaluate the
proposed rules. The "Attachers' Proposals" consistently align with the goals of reducing delays
and fostering predictable, rapid broadband expansion while prioritizing safety as a paramount
concern. Conversely, the "Utility Proposals" inject ambiguity, grant utilities excessive unilateral
discretion, and institutionalize the very delays that House Bill 180a was enacted to prevent.
The ICBA urges the Commission to adopt the Attachers' Proposals, which are more in line with
the intent of H180a and are designed to ensure Idahoans receive the benefits of broadband
deployment without further delay, and which also and equally protect utility ratepayers from costs
related to third-party pole attachments.
Rule 0: Legal Authority
The Utility Proposal to add a broad waiver provision allowing the Commission to waive any rule
for "good cause shown" should be rejected. Such a vague and open-ended provision undermines
the very purpose of this rulemaking and is directly contrary to the mandate of H180a to "establish
rules" that are "related to the timing of the permitting process for pole attachments" (I.C. § 61-
538(5))to "reduce delays and increase deployment" of broadband facilities throughout Idaho.
Moreover, serious issues arise where an administrative agency—on its own motion or that of a
third party—has the legal authority to waive its own rules, especially where it is explicitly directed
otherwise by the legislature to create such rules.
Rule 3: Definitions
The Utility Proposal to amend the definition of"Attaching Entity"to include"multiple subsidiaries
from the same parent company" is an anticompetitive and operationally unworkable measure that
must be rejected. This proposal is a transparent attempt to artificially aggregate separate and
distinct projects to push them into the longer timelines for"Mid-Sized" or"Large Orders."
A parent company may have one or more subsidiaries operating in Idaho for legitimate business
reasons—serving different geographic markets, specializing in different technologies (e.g.,
residential fiber vs. enterprise wireless), or managing different funding sources. To treat a 200-
pole rural fiber build from one subsidiary as part of a 200-pole urban wireless project from another
subsidiary simply because of a shared parent company is contrary to the legislative intent to
streamline and shorten the time period for pole attachments. It forces disparate projects onto a
single, slower track, directly contravening the legislative intent to "reduce delays." For example,
the FCC's framework correctly allows a utility to treat multiple requests from a single attacher as
one request only when they are filed within 30 days of one another but does not provide for the
aggregation of affiliated companies. As Idaho looks to deploy rural broadband facilities,
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aggregating a rural build from one company with an urban build of an affiliated company frustrates
the legislative intent of H180a.
Rule 4: Timelines
Predictable timelines are the bedrock of efficient broadband deployment. The FCC has repeatedly
found that "in the absence of a timeline, pole attachments may be subject to excessive delays."
The Attachers' Proposal provides a clear, workable framework that aligns with federal best
practices. The Utility Proposal,however,introduces several elements designed to extend timelines
and create uncertainty that will result in both facility deployment delays that will threaten
compliance with federal grant requirements, and undermine the timely delivery of broadband and
other services to companies whose lifeblood fully depends on online commerce and virtual
collaboration. Such delays will place Idaho companies at a distinct competitive disadvantage
compared to jurisdictions who follow the FCC Make Ready doctrine.
First, the use of business days instead of calendar days in the Utility Proposal is a subtle but
significant method of extending project timelines. The utilities used the number of days, to
complete the various steps in the attachment process, that are used in the FCC's access timelines
with the exception of application re-review and above communications space make-ready, where
they have extended the days to complete those steps. However, and importantly, the utilities have
changed how the days are calculated. The FCC's timelines are based on calendar days, and the
Utility Proposal is based on business days. This change in how timelines are calculated would add
four to six months to the already lengthy attachment process. As proposed by the utilities, if an
attacher needed to attach to 500 poles, it would take nearly 18 months before an attacher could
start constructing its facilities. Additionally, this complication of using business instead of
calendar days adds unnecessary administrative burden and reduces predictability, especially for
projects spanning several months where holidays can accumulate to add weeks of delay. The use
of calendar days,as proposed by the attachers,is more straightforward and is the standard by which
the FCC timelines—as the utilities base their proposal—calculates days. Moreover, the ICBA is
unaware of any other reverse preemption states that calculate access timelines in business days.
Second, the Utility Proposal to commence the timeline for all aggregated applications on the date
the last request is received is profoundly inefficient and must be rejected. This creates a rolling
delay where an attacher is penalized for submitting additional applications. For example, if an
attacher submits a 50-pole application on day 1, the clock should start. If they submit another 50-
pole application on day 25, it is reasonable to aggregate them into a 100-pole "Mid-Sized Order."
It is not reasonable to suggest the clock for the first 50 poles should be reset and only start on day
25.
Third, the Attachers' Proposal for managing large orders is reasonable and modeled directly on
the FCC's recent findings. The FCC adopted a rule requiring attachers to provide advance written
notice (at least 60 days for large orders) and mandated a meet-and-confer requirement before the
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application is submitted. This pre-planning allows utilities to assess resource needs and for both
parties to "negotiate in good faith the mechanics and timing by which such orders will be
processed." The Attachers' Proposal mirrors this logical, proactive approach- In contrast, the
Utility Proposal calls for a meet-and-confer only after an application for over 1,000 poles is
submitted, a reactive measure that fails to provide the advance planning utilities claim they need.
The FCC's approach,reflected in the Attachers'Proposal,fosters the collaboration needed to make
large deployments successful.
Finally,and most critically,the order sizes proposed by the utilities are far too small and effectively
negate the streamlining intent of H180a. The Utility Proposal caps "Large Orders" at 1,000 poles,
a number that is drastically out of step with the scale of modern broadband projects, particularly
those funded by federal and state grants. These grant-funded deployments, which the legislature
explicitly sought to accelerate, will almost certainly be delayed by order sizes proposed, which
risks delaying projects to the point where Idaho may lose federal funding. As proposed by the
utilities, it would take an attacher approximately 9 months before it was allowed to begin
attachment for small orders (i.e., 100 or fewer poles); over a year to begin attachment for mid-
sized orders(i.e., 100—500 poles); and nearly 18 months for a large order(i.e., 501 - 1,000 poles).
These lengthy timelines for such small numbers of poles are untenable and will only serve to
compound permitting delays. Moreover, and as discussed above, any argument by the utilities that
the number of poles in their proposed order sizes should remain because the utilities would not
have time to ramp up resources to process any higher numbers of poles is unpersuasive. As
proposed, attachers would be providing the utilities at least two months advanced notice prior to
submitting for a large order, or 15 days for any mid-sized order associated with a single network
deployment project to allow time for the utilities and attachers to plan and prepare for those
deployments.
The FCC, in its recent Fifth Report and Order, conducted a thorough national analysis and
established a modern, realistic framework for order sizes that Idaho should adopt as the gold
standard. The FCC's framework is designed to handle the "significant increase in the number of
applications seeking to attach these facilities to large numbers of utility poles" driven by historic
government investment. The ICBA urges the Commission to reject the utilities' inadequate size
categories and instead adopt the following structure:
• Regular Orders: Pole attachment requests up to the lesser of 300 poles or 0.5%
of the utility's poles in a state.
• Mid-Sized Orders: Orders exceeding a Regular Order up to the lesser of 3,000
poles or 5% of the utility's poles in the state.
• Large Orders: Orders exceeding a Mid-Sized Order up to the lesser of 6,000 poles
or 10% of a utility's poles in a state.
Adopting the FCC's well-vetted size categories is the only approach that aligns with the legislative
mandate of H180a. It creates a predictable timeline for the vast majority of broadband projects
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currently being planned and funded,preventing the artificial delays that would be institutionalized
by the utilities'proposal.For Idaho to capitalize on this"historic investment in broadband,"it must
have a regulatory framework that reflects the reality of modern network deployment, not a
restrictive structure designed to create bottlenecks.
Rule 5(b): Non-Discriminatory Access; Denial of Access
The Utility Proposal would grant utilities an unreasonable level of autonomy and authority to deny
access to essential infrastructure. First, the ICBA agrees that utilities should be allowed to deny
access for reasons related to pole space capacity, or for reasons related to "safety, reliability, or
generally applicable engineering purposes," so long as those reasons are documented in writing
and sufficiently explained. By way of comparison, Section 224(f) of the Communications Act
permits denial only for specific, verifiable reasons: insufficient capacity, safety, reliability, and
generally applicable engineering standards.
However, the ICBA objects to the denial of access for arbitrary, vague and undefined reasons, for
example, the inclusion of language allowing utilities to deny access for "failure to meet
standardized credit requirements demonstrating the financial health of an attaching entity."
Although all ICBA member companies are financially healthy, the ICBA objects to the inclusion
of such language since such terms are vague and undefined in rule or statute. Furthermore, the
ICBA objects to denial of new pole access for"uncured violations"related to existing attachments,
which alleged "uncured violations" can be nothing more than a utility's mistaken or arbitrary
allegation, and which in any event, are extensively dealt with in a pole attachment agreement
between a utility and an attacher. Even if a violation is uncured,it may have already been identified
by the utility and the attacher, with the parties working towards resolution with a corrective action
plan already in place. Denying access under such a scenario would be highly inappropriate and an
unnecessary hindrance to broadband deployment.
Rule 6: Make-Ready Work
The Utility Proposal's list of justifications for "good and sufficient cause" to delay make-ready
work would effectively nullify the timelines established in Rule 4. Including vague, internal, and
unverifiable conditions like "pole owner capacity to process requests," "engineering complexity,"
or "lack of qualified contractors" as valid reasons for delay is unacceptable. Utilities should not
be empowered by rule to delay attachments because of"complexity" in the abstract or because
they"lack resources"to process applications.
Instead, utilities should hire and train adequate staff to process pole attachment applications or
retain and train outside contractors to process the same, an expense that is recoverable in utility
rates, either in the utility's next general rate case, or if the utility believes such expenses are
significant or extraordinary,through the filing of an application with the PUC to create a regulatory
asset that tracks pole attachment processing expenses and recovers such regulatory asset in its next
general rate case.
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In addition, and as contained in the attacher's alternative, if the utility does not have sufficient
internal staff or outside contractors to process make-ready requests, attachers should have the
option of selecting a mutually-acceptable third parry contractor to perform the critical steps in the
attachment process: (1) surveying; (2) engineering, (3) estimating, and (4) make-ready, both in
and above the communications space, when the applicable deadlines are missed. This provides a
clear path forward when delays occur. The Utility Proposal, by contrast, only offers excuses for
those delays. Furthermore, the Utility Proposal strikes the inclusion of the terms "engineering,
surveying, and estimating". These are not simply further descriptive terms, but separate and
distinct steps in a process that are a pre-requisite before make-ready work can begin, and all of
which must be completed before an attaching entity may begin deploying its facilities. The ICBA
strongly objects to the striking of such terms which are defined and included in the regulatory
frameworks of many of Idaho's neighboring states.
Rule 7: Safety
While public safety is a shared, paramount goal, the Utility Proposal for Rule 7 grants utilities
overbroad authority based on "sole discretion" to remove attachments for non-emergency reasons.
This subjective standard could be misused to disrupt or shut down a provider's network, which is
also dedicated to public safety and may provide emergency services such as 911 connectivity,
service to first responder offices and hospitals, or schools.
Rule 8: Enforcement
The enforcement mechanisms for unauthorized attachments are complex issues that are most
effectively handled through negotiated Pole Attachment Agreements (PAAs). These bilateral
agreements establish detailed notice-and-cure provisions, escalating penalties, and dispute
resolution procedures tailored to the specific parties. Mandating a single, inflexible penalty
structure in state rules, as the Utility Proposal suggests, potentially supersedes and potentially
illegally nullifies negotiated agreements concerning the same issue. As proposed by the Attachers,
these matters are better left to the PAA.
Overlashing
While the proposed rules do not explicitly address "overlashing," the principles they establish for
streamlining broadband deployment underscore the critical need for rules addressing this specific
type of attachment. Overlashing—the process of lashing a new cable to an existing cable strand
is a common, efficient, and minimally invasive method for upgrading and expanding network
capacity. The FCC's Third Report and Order and Declaratory Ruling (FCC 18-111) addresses the
overlash process in detail. At a high level, this rule prohibits a utility from requiring an attacher to
submit a full application for overlashing or receive prior approval before proceeding with planned
overlashing, and requires an attacher to provide up to fifteen (15) days' advanced notice prior to
performing planned overlashing. During the 15-day notification period, a utility is allowed to
perform engineering, at their cost, to determine if the proposed overlashing would create a safety,
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reliability, or engineering issue. If the proposal would cause any of those issues, the utility is
required to provide specific documentation of the issue to the attacher within that 15-day period
and the attacher must address it prior to overlashing — either by modifying its proposal or
explaining why modification is unnecessary. When proceeding with planned overlashing, the
attacher is responsible for ensuring that its overlashing complies with reasonable safety,reliability,
and engineering practices, and is responsible for any damage caused by the overlashing or
overlashing work. After an attacher completes its overlashing, it must provide notice to the utility
and permit the utility to inspect the Overlash. The inspection must happen within three months,
and if the utility identifies any damage caused by the overlashing or overlashing work,must notify
the attacher within two weeks after inspection, and the damage must be corrected at the attachers
cost two weeks thereafter. Note, the FCC was clear that the risks imposed by overlash are so
minimal as to not warrant in-depth scrutiny. Without addressing the overlash process, or worse
yet, lumping it together with standard Make Ready, the overlash process will be subjected to the
same lengthy review processes as complex new attachments requiring significant make-ready
work. This creates an unnecessary bottleneck that directly conflicts with the Idaho Legislature's
stated intent to "reduce delays and increase deployment".
The ICBA respectfully requests the inclusion of the FCC's rules on overlashing promulgated under
47 C.F.R. § 1.1416. Establishing a distinct and predictable process based on the FCC's findings
and Order to manage the overlash process is a logical and necessary step to ensure that simple,
low-impact network enhancements can proceed swiftly, promoting the efficient use of existing
infrastructure and accelerating the delivery of better broadband to Idahoans.
Self-help
As with overlashing,the proposed rules also do not mention the self-help remedy that prominently
features in the federal rules and has proven to be of great benefit to many ICBA members by
reducing incessant utility created make-ready delays while increasing efficiency and lowering
costs. Utilities often fail to timely notify applicants of their inability to process pole attachment
applications in a timely manner, which diminishes the utility and value of the self-help process.
Not wishing to see the usefulness of this process compromised in this manner the recent FCC Fifth
Report and Order now requires utilities to notify attachers within 15 days of receipt of a complete
application if the utility knows that cannot meet make-ready deadlines, after which attachers may
immediately exercise self-help. Further, the recent federal rulemaking expands attacher self-help
to include make-ready estimates for work in and above the communications space.
Mindful of the legislature's finding that"[p]ermitting delays have hindered broadband deployment
in the state despite historic investments in broadband" the Commission should recognize the
usefulness of self-help to avoid utility delays and speed the efficient deployment of broadband
facilities as the Legislature intends.
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Conclusion
The Idaho Legislature has recognized that the path to ubiquitous broadband requires a modern,
efficient, and transparent pole attachment process. This rulemaking must fulfill the legislative
mandate to "reduce delays and increase deployment." The Attachers' Proposal provides a
comprehensive framework to achieve that goal. It promotes collaboration through advance notice,
ensures predictability with firm timelines and clear standards, and demands transparency when
access is denied. The Utility Proposal consistently seeks to create loopholes, extend deadlines,
grant itself unilateral discretion, and preserve an outdated system that has already been identified
as a hindrance to broadband investment.
For the economic future and public safety of all Idahoans, the ICBA requests the Commission to
adopt the Attachers' proposed alternative rules where noted.
Sincerely,
(JV�
on Williams
ICBA Executive Director
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