UTC and EEI yesterday filed detailed comments in opposition to the FCC proposals to change the pole attachment rules. In summary, the FCC's latest pole attachment proposals would further subsidize the communications industry at the expense of electric customers and would undermine the safety and reliability of the nation's electric grid; and, that’s not a great formula for success. Our major concerns are proposals for new "timelines for make ready," Allowing use of third party contractors for make ready, creation of a pole attachment database that would reveal the location of critical facilities, new compensatory damages for failure to strictly comply with the new rules, and low, sub-cable rates for telecommunications attachments. In too many instances, these proposals would put utilities in the position of either breaking the rules or putting the employees and customers at risk. We know what utilities will do and fervently believe it is wrong to penalize utilities for ensuring safety. Additionally, the proposal has the FCC, which takes great pride in regulatory transparency, continuing policies of hiding the cost of broadband deployment in utility customer bills. The UTC/EEI comments are worth reading for a good understanding of the current pole attachment debate. If you still have questions, contact Brett Kilbourne, Director of Regulatory Services & Associate Counsel UTC at 202.833.6807 or brett.kilbourne@utc.org.