If you have been following industry news or reading our blogs, you may know by now that the Federal Communications Commission has passed a Report and Order called One Touch Make Ready (OTMR). OTMR is a set of guidelines designed to speed up deployment and prepare the nation for 5G technology.
The possible influence of OTMR is big. “By some estimates, OTMR alone could result in approximately 8.3 million incremental premises passed with fiber and about $12.6 billion in incremental fiber capital expenditures,” the FCC's order states.
Are You Ready for One Touch Make Ready?
So, what are the basics of the new Report and Order? Here 6 fundamentals of OTMR:
- It vetoes moratoria.
- It permits overlashing.
- It requires contractors to perform safe and reliable OTMR work. Utilities are encouraged to create their own lists of approved contractors. If they don’t do so, attachers may use the FCC’s requirements to hire qualified contractors.
- It sets time limits for completing make-ready work.
- It puts a bigger responsibility of make-ready work in the hands of the new attacher.
- It establishes procedures that must be followed if existing equipment is damaged during installation of a new attachment.
To read more about the bare basics of OTMR, read our blog post: Are You Ready for One Touch Make Ready?
FCC Regulation and OTMR
The order establishes a variety of new requirements that the joint use community must meet. The joint use community includes asset owners, attachers, contractors, third parties, and other professionals who handle joint use administration. The FCC states the requirements of the joint use industry will help replace the prior vague guidelines with specific guidelines.
The role of each community member will change under OTMR. Some responsibilities and rights have been shifted from one party to another. Existing attachers have a much smaller role in the process.
It is also important that joint use parties understand that One Touch Make Ready rules apply only to simple attachments in the middle (or “communications space”) of a utility pole. Attachers at the top (or “electric space”) of the pole must follow a multi-touch process.
Shortening the deployment time for new broadband and small cell attachments is the main purpose of OTMR, but it’s also one of the biggest challenges. Here’s a before-and-after comparison of some steps in the process:
Application Review
Before: The process was vague for asset owners to determine whether an application for an attachment was complete, and there was no established timeline for making that determination.
After: OTMR makes clear what must be included in the application. It gives asset owners 10 days to determine whether the application is complete.
Decision and Survey
Before: The asset owner had 45 additional days to decide whether to grant the application and complete any necessary pole and equipment surveys.
After: The asset owner has 15 days to decide, and the new attacher conducts the survey.
Make-Ready Work
Before: Once notified by the asset owner, existing attachers had 60 days to prepare the pole for the new attacher. Then, the asset owner had 15 additional days to complete make-ready work.
After: The new attacher performs all work in (as little as) one trip. It must provide 15 days of notice to existing attachers before beginning the work, but that notice may begin while the asset owner is deciding whether to grant the application.
The FCC states that, while OTMR gives new attachers more control over the speed of deployment, it also relieves asset owners of some of the responsibilities and costs they had to bear under the old rules.
To read about the specifics of new policies and joint use roles under the OTMR guidelines, check out our blog: Challenges with FCC Internet Regulation and One Touch Make Ready
Getting Started: Contractor Selection
A vital step of OTMR is the new attacher’s selection of contractors to perform its required surveys and make-ready work. The OTMR order urges pole owners to set standards for third-party contractors and to provide new attachers with lists of approved contractors.
If a list is provided, the attacher must select a contractor from that list. If the asset owner does not offer a list of approved contractors, the attacher may select a contractor using the FCC’s minimum requirements.
Getting Started: Attachment Installation
With the advantages OTMR gives to new attachers, it also insists some requirements. Below are three requirements of new attachers:
Providing Notice
The new attacher must give the asset owner and existing attachers notices before performing asset surveys or beginning any make-ready work. The notice gives the asset owner and existing attacher an opportunity to be present. The notice must include the place and time the work will be done, a description of the work, and the contractor’s name.
Correcting Damage or Outages
If the new attacher’s contractor damages existing equipment or causes an outage, it must stop work immediately. The new attacher is required to notify the asset owner and existing attachers that have been affected. The owner may require the new attacher to repair damages or equipment, and bill the new attacher for the work. The repairs take precedence over finishing make-ready.
To read more about the contractor selection process and attachment installation, visit our blog post: Getting Started with OTMR: Make Ready Work
Utilizing OTMR to its Full Potential
One Touch Make Ready may seem overwhelming due to its massive changes in previous processes, but the order holds many benefits for both pole owners and attaching companies. The promise of OTMR is to speed broadband deployment in preparation for 5G and the development of the IoT. The OTMR-Based Regime promotes all joint use parties working together for the benefit of these goals.
Here are a few promises made by the order that support fast, safe, and reliable deployment:
Common Sense
Although the new regulations will require a hefty transition, OTMR brings a sensical approach to the joint use world. Requiring all companies to coordinate on the same processes will produce long-term benefits.
No More Stalling
Faster broadband deployment has been a request of many organizations, companies, consumers and the FCC for some time. With the new OTMR policy, swift deployment is no longer a pipe dream. OTMR requires timelines and deadlines by all joint use parties for basically every part of the joint use process.
A Well-Defined Process
Like most things in life, One Touch Make Ready is what we make of it. With the new timelines, reduced costs, and rules provided by the FCC, the policy offers a defined process for the joint use community to adhere by. If all companies are working on the same deadlines and timetables, while complying with OTMR-Based Regime, the process will begin to run itself.
To understand the promises that OTMR offers to joint use professionals, read our blog: The Promises of One Touch Make Ready (OTMR)
Preparing for One Touch Make Ready
At Alden, the question we are hearing the most about OTMR is: “Where do I get started?” Companies can transition to OTMR timelines and policies by taking a few simple steps.
For asset owners, the first step is to cultivate a list of qualifications for contractors, based on the OTMR guidelines. The next step is building a list of approved engineering and construction contractors who are qualified to work on their utility systems.
For attachers, the first step is get familiar with the authorized-contractor list of requirements and to reach out to local asset owners for their lists.
The next step all parties is to update points of contact. Since notices must be sent to all parties during steps of OTMR, having updated contact lists will make the process run smoothly.
Read more about how to prepare your staff for the new OTMR policy: Preparing Your Staff: One Touch Make Ready and Broadband Deployment
Maximizing Resources
At Alden, as we dig deeper through consulting, we are learning that many companies have current staff members who are already bogged down by repetitive manual data entry. They are dividing their attention among multiple systems to complete one joint use process. With these redundant practices in place, jumping into a change as big as OTMR is making joint use departments feel stressed. Carrying on with the hope of working it out along the way is a recipe for chaos, failed FCC compliance, and missed deadlines.
Fortunately, there are alternative solutions and processes. Companies can make a streamlined transition to OTMR with their joint use personnel. The key is getting started the right way.
Alden has created an automated workflow for our joint use platform, Alden One®. Our platform ensures compliance, and helps companies coordinate with other parties. Here are six features of our OTMR workflow that guarantee compliance:
- Alden One® guarantees FCC timelines will be met through automated timers.
- Communication tools provide users the ability to work in one system with all OTMR parties, ensuring coordination.
- The system stores a list of authorized contractors, pole attachment agreements, contracts, points of contact, and pole locations.
- The OTMR workflow enables users to send out the required notices for each step.
- All activities are logged to demonstrate compliance, when needed.
- Dashboards show a high-level view of all activities so that businesses can make data-driven decisions.
Alden consultants are available to help companies get OTMR compliant. Our goal is to help owners and attachers save their energy and time during this complex new process.
If you are struggling with where to begin or how to put compliant processes in place, reach out to one of our product specialists to discuss how a joint use platform can help your company transition to OTMR. We are here to walk with you through every step.