Thank you for providing R Street Institute the opportunity to comment on this Further Notice of Proposed Rulemaking (FNPRM). As you are aware, on March 16 the Federal Communications Commission (FCC) voted to seek comment on ways to ensure that broadband deployments are efficient and costs are shared between both pole owners and pole attachers. R Street is encouraged that the Commission recognizes the importance of enabling quick and predictable access to poles in order to improve broadband buildout and respectfully submits the following articles for consideration as part of the record:
Jeffrey Westling, Pole Replacement Explainer, R Street Institute, Apr. 2021. https://www.rstreet.org/wp-content/uploads/2021/04/explainer23.pdf
Jeffrey Westling, “Barriers to Broadband Deployment,” R Street Institute, Nov. 9, 2021.