The American Cable Association ("ACA") files these comments in response to the Commission's Further Notice of Proposed Rulemaking seeking comment on certain pole attachment reforms.  ACA commends the Commission for "begin[ning] the process of revising the Commission's pole attachment rules to lower the costs of telecommunications, cable, and broadband deployment and to promote competition... ." ACA supports many of the reforms proposed in the FNPRM, and urges the Commission to:

• Retain the existing cable rate for cable operators providing commingled video and Internet services.
• Consider the impact additional pole attachment related fees have on broadband deployment and consumers.
• Implement a make-ready process timeline.
• Allow attachers to use outside contractors to perform surveys and make-ready work if a utility has failed to perform its obligations within the timeline proposed by the Commission.
• Permit applicants to pay make-ready charges in stages.
• Require utilities to make a schedule of make-ready charges available to attaching entities.
• Enumerate in its rules the remedies available to an attacher that proves a utility has unlawfully delayed or denied access to its poles.
• Specify in its rules that compensatory damages may be awarded where an unlawful denial or delay of access is established, or a rate, term, or condition is found to be unjust or unreasonable.
• Retain the current "sign and sue" rule.

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