The Edison Electric Institute filed a Report and Supplemental Declaration that provides an economic analysis of the FCC's pole attachment rate policies. It concludes that the existing rates for cable television and telecommunications attachments significantly subsidize the communications industry and discourage electric utilities from making investments in distribution infrastructure. The Report further concludes that these subsidies and their dampening effect on infrastructure investment would be exacerbated if pole attachment rates were based on marginal costs as proposed in an economic study filed by the cable television industry. Specifically, the Report finds that the existing rates do not account for the full capital and operating costs of pole attachments and that make ready charges, which recover incremental costs, only cover a "small fraction" of electric utility costs associated with pole attachments. The Report also finds that proposed reductions to various carrying charge elements of the FCC’s rate formulae (including the maintenance, interest and administration elements) would exacerbate the subsidy. Declaring that the FCC's presumption of attaching entities in urban and non-urban areas "do not reflect reality" thus subsidizing the cost of pole attachments further. For more information, contact the UTC Legal/Regulatory Department.