Develop A Clear Broadband Plan 0 Ensure commitment of community stakeholders, including local •overnment •ersonnel

Permit innovative construction techniques

Define an expeditious process for on-going permitting and ins•ections

Build out requirements have been proven counterproductive

Publish data about existing infrastructure

Allow prospective attachers to perform all make-ready work themselves throu • h contractors

Install ubiquitous fiber conduit Provide space on all poles for ne attachers

USE OF EXISTING INFRASTRUCTURE

3itat

Make all rights-of-way available on clearly defined, reasonable terms throu • h a ra • id a royal • rocess

Make poles available on clearly defined, reasonable terms through a ra • id a royal • rocess

Ensure make-ready work is performed expeditiously

PROACTIVELY IMPROVING EXISTING INFRASTRUCTURE

(14 Use building codes and community development plans to drive fiber de lo ments

COMMUNITY AND LOCAL GOVERNMENT LEADERSHIP

AND SUPPORT

APPROVAL REQUIREMENTS AND PERMITTING

Coordinate all pole maintenance and make-ready work with the new •rovider to save costs

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FIBER-FRIENDLY COMMUNITY

Communities across the country understand the great value of gigabit broadband and are exploring how they can encourage the deployment of fiber-to-the-home (FTTH) networks to support this technology.

Some key factors are within the control of a community... In other words, a community can make a real difference in whether a network gets built.

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Becoming a Fiber-Friendly Community Regulatory and Infrastructure Actions That Can Drive Deployments

Communities across the country understand the great value of gigabit broadband and are exploring how they can encourage the deployment of fiber-to-the-home (FTTH) networks to support this technology. A wide range of factors drives the decision to deploy a FTTH network, from the cost of construction and operation to demand for service. Importantly, some key factors are within the control of a community, such as accessing public rights-of-way and government owned facilities and receiving government permissions. The Federal Communications Commission (FCC) estimates these factors may amount of 20% of the total deployment cost. In other words, a community can make a real difference in whether a network gets built.

In this paper, we outline a series of steps that communities should consider to clear a path for and work with a prospective broadband provider. It is not exhaustive, and some of the steps require cooperation from other private and public actors to achieve. Further, the trade-offs among competing objectives and degree of difficulty in finding solutions will vary among communities. But achieving these benchmarks has the potential to meaningfully reduce deployment costs and tip the balance in favor of FTTH network investment in your community.

Community and Local Government Leadership and Support From initial conception to contract negotiations to construction and operation of the network, community leadership — from government officials, community leaders, and business owners --play a crucial role at every step of the deployment process.

Develop a clear broadband plan: Deploying FTTH is a critical step for communities to participate fully in the rapidly evolving Internet economy. Like other major community infrastructure projects, construction of this network is a major undertaking, with large costs incurred up front prior to any service being provided and revenues flowing. As such, communities need to have a clear vision about the nature of the undertaking and, once committed, develop a culture to support this effort — one that will last as community

leadership changes over time and unexpected circumstances arise. A crucial part of any community plan is to set realistic goals for the project and define precisely the community's investment and involvement. The plan, for instance, should discuss how

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the community will directly benefit from the FTTH deployment, including connectivity and use of the network at public institutions, as well as consider how individual's use at home can improve access to and use of relevant civic services. That way, there can be broader commitment to the project from within the community at large.

Ensure commitment of community stakeholders, including local government personnel: It is essential to have key community stakeholders, especially local government decision-makers and relevant personnel, available throughout the deployment process. Appointing a single government official as point of contact responsible for all parts of the project is one way to facilitate deployment. Local governments also should designate a team responsible for cooperating with the FTTH network provider on a day-to-day basis.

Approval Requirements and Permitting There are various permitting and approval processes necessary to build an FTTH network. Here, states may have a role, such as where the state has adopted a state issued franchise for access. However, in most instances, the local government will control the rights and processes. Any approval process needs to have reasonable substantive requirements and be completed expeditiously. In addition, comprehensive approval for an entire project, instead of repeated approval requirements for different stages of a project, greatly reduces delays that add costs to a project.

Define an expeditious process for on-going permitting and inspections: All applications for permits should have a guaranteed response deadline — preferably no more than 5 business days. Along with providing a dedicated inspection team, local governments should allow providers to work with a pre-approved, third-party inspection team to review all work in a timely manner.

Permit innovative construction techniques: Providers are constantly developing new technologies that speed deployment, minimize disruption to ongoing activities and reduce any costs for local governments. Microtrenching is an example of these innovations and is currently permitted in many areas. Local governments should be open to permitting expeditious use of such new techniques.

Mandated deployment requirements are counterproductive: Imposing "must build" requirements on a new entrant in a market has proven counterproductive to new builds and has been seen by federal and state agencies as anti-competitive because they end up making projects uneconomical and entrenching incumbent providers. As such, local governments should not impose these requirements on new entrants. This does not mean

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that communities should set aside legitimate concerns about ensuring access is provided ubiquitously. Rather, local governments should work with providers on alternative, more flexible ways to ensure access reaches customers who want service.

Use of Existing Infrastructure The ability to access existing infrastructure can dramatically reduce the costs of FTTH deployments. It is crucial to ensure all prospective providers can secure rapid and uninterrupted access to this infrastructure at a reasonable and predictable cost in a timely manner.

Publish data about existing infrastructure: For providers to make use of infrastructure, they need to know what is available. To the extent consistent with public safety, welfare, and related concerns, local governments should seek to provide data to providers regarding conduit, ducts and other public or proprietary rights-of-way it owns or controls as well as local government poles and buildings to which providers can attach equipment.

Make all rights-of-way available on clearly defined, reasonable terms through a rapid approval process: Local governments should make available standard forms related to all rights-of-way and easements they own or control. The price for access should be commensurate with the actual additional cost imposed by the provider and incurred by the local government. Pricing and terms should be published and offered on a fair and reasonable and competitively neutral basis. As with permitting generally, any on-going approvals should occur within 5 business days.

Make poles available on clearly defined, reasonable terms through a rapid approval process: Running fiber aerially along utility poles is often significantly cheaper (and less intrusive) than running fiber underground. Poles can be controlled by local governments or their affiliated entities, cooperatives, or privately-owned utilities. Where local governments or their affiliates own or control poles, they should adopt clear, predictable rules for providers to attach their wires and equipment across to these poles on a fiar, reasonable, and competitively neutral basis. In addition, local governments should endeavor to work with cooperatives and private utilities to facilitate access by providers to their infrastructure on fair and reasonable terms.

The FCC's rules enable providers of telecommunications services and cable services (and broadband service offered in combination with one or both of these services) to attach equipment to poles owned/controlled by private utilities at just and reasonable rates and a schedule for the application, survey, and make-ready process. Since this right might not apply where a provider only offers standalone broadband Internet access service, local governments should seek to ensure that these providers have attachment rights on

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equitable terms comparable to those covered by the FCC's rules. Finally, as permitted by the federal statute, many states have adopted their own pole attachment statutes or regulations, which may not only apply to private utilities but to government utilities and cooperatives that own/control poles.

Ensure make-ready work is performed expeditiously: Rearranging existing attachments and other steps necessary to make a pole ready for an additional attacher can add significant delay and cost to broadband deployment. In general and subject to government oversight, pole owners are responsible for this work and should complete it in a reasonable amount of time. If pole owners (and, where relevant, other attachers) are not complying, prospective attachers should have the right to complete the work themselves. For poles owned/controlled by local governments, there should be established prices and timelines for these services that are comparable to those provided for in the FCC's rules.

Coordinate all pole maintenance and make-ready work with the new provider to save costs: Every pole is maintained by its owner on a periodic basis, although this period may be in excess of ten years. Where possible, a local government should seek to align pole maintenance that benefits itself and all attachers with a provider's deployment schedule such that any make-ready work can be done at the same time. To facilitate this process, providers should identify the set of poles that they intend to use first, and these should be prioritized as part of maintenance cycles. This way, rather than having two sets of crews work on the pole -- one for the regular maintenance and one to make it ready for fiber -- there need only be one set of work on the pole and thus one set of labor costs. (Providers attaching to poles should only pay for the portion of the work directly related to their attachment.)

Allow prospective attachers to perform all make-ready work themselves through the use of independent, approved contractors: To facilitate an even faster deployment process, local governments should enable prospective attachers to perform surveys and make-ready work themselves working with a set of pre-approved contractors, without having to get further permissions from the existing attachers. For instance, by setting clear standards for companies to become approved make-ready contractors, the local government can help drive down the timeline for surveys and make-ready work and speed fiber deployment. Moreover, having contractors work directly with prospective attachers aligns incentives in ways that can make the process move along faster.

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Proactively Improving Existing Infrastructure Some of the more significant cost reductions can come from communities instituting a forward-looking program to improve existing infrastructure. While some of these actions requires investment, it will provide a more conducive environment for providers in the long run and has the added benefit of reducing the government's construction and maintenance costs.

Provide space on all poles for new attachers: Where they have authority, local governments can take pole maintenance one step further, by proactively providing space on the pole for providers. One way to do this is by expediting standard maintenance work and performing make-ready work at the same time.

Install ubiquitous fiber conduit: By installing conduit for fiber with enough space for additional networks, local governments can limit the need for providers to engage new construction, further expediting fiber projects. For instance, the government could adopt a "dig once" policy, such that fiber conduit is installed any time road construction occurs. By doing so, the cost of that construction is amortized over all projects that later utilize the conduit, reducing costs and minimizing disruption to drivers. This can reduce deployment costs along roadways by as much as 90%, while adding less than one percent to the cost of the road construction.

Use building codes and community development plans to drive fiber deployments: It is common for local governments to set basic standards regarding minimum levels of service for homes, residential planned communities and residential and commercial buildings. Local governments should require that new construction and substantial renovations for buildings and new community plans to include structured wiring that allows fiber to be run easily to each room within a home or multiple dwelling unit.

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