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El Negociado de Telecomunicaciones (NET) de la Junta Reglamentadora de Servicio Público emitió una resolución y orden de emergencia estableciendo una tarifa provisional por el uso mancomunado de los postes de la red eléctrica y programar un procedimiento adjudicativo con el propósito de determinar una tarifa formal y atender otros asuntos relacionados con el uso de los postes de transmisión y distribución de la Autoridad de Energía Eléctrica (AEE) los cuales son administrados por LUMA Energy.
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0% encontró este documento útil (0 votos)
1K vistas18 páginasDocumento: NET-2024-PA-0001
El Negociado de Telecomunicaciones (NET) de la Junta Reglamentadora de Servicio Público emitió una resolución y orden de emergencia estableciendo una tarifa provisional por el uso mancomunado de los postes de la red eléctrica y programar un procedimiento adjudicativo con el propósito de determinar una tarifa formal y atender otros asuntos relacionados con el uso de los postes de transmisión y distribución de la Autoridad de Energía Eléctrica (AEE) los cuales son administrados por LUMA Energy.
Cargado por
La Isla OesteDerechos de autor
© © All Rights Reserved
Nos tomamos en serio los derechos de los contenidos. Si sospechas que se trata de tu contenido, reclámalo aquí.
Formatos disponibles
Descarga como PDF o lee en línea desde Scribd
GOVERNMENT OF PUERTO RICO
PUBLIC SERVICE REGULATORY BOARD
TELECOMMUNICATIONS BUREAU
IN RE: THIRD PARTY POLE ATTACHMENTS | CASE NO.: NET-2024-PA-0001
TO PUBLIC T&D POLES IN PUERTO RICO
SUBJECT: Emergency Order to Establish and
Enforce Pole Attachment Fees and For Other
Purposes
EMERGENCY RESOLUTION AND ORDER
‘This Emergency Resolution and Order is issued by the Telecommunications Bureau of Puerto
Rico of the Public Service Regulatory Board (“TBPR” or “NET” by its Spanish acronym) to: (i)
establish and enforce pole attachment fees for the usage of government-owned
Transmission and Distribution ("T&D") poles; (ii) resolve the allocation of equipment
transfer costs related to the replacement of publicly-owned T&D poles, (iii) clarify new
attachment and make-ready issues, and (iv) schedule an adjudicatory proceeding to address
pole attachment matters.
I. _ FINDINGS OF FACT AND PUBLIC POLICY
On June 22, 2020, PREPA, the Puerto Rico Public-Private Partnerships Authority (“P3A") and
LUMA Energy LLC with LUMA Energy Servco LLC (collectively “LUMA”) entered into an
Operations and Maintenance Agreement ("O&M Agreement”). The O&M Agreement
entrusted LUMA with the management of PREPA’s entire T&D system, including all poles.
The Government of Puerto Rico, acting through the Puerto Rico Electric Power Authority
(‘PREPA’), retains ownership of the T&D grid in Puerto Rico, and as per information received
by the NET, LUMA manages approximately 637,000 publicly owned T&D poles.
In accordance with Act No. 213 of September 12, 1996, known as Puerto Rico
‘Telecommunications Act (“Act 213") the NET is responsible for regulating and supervising
all T&D pole attachment issues involving public property. Several issues concerning the
usage of government-owned T&D poles persist, causing a substantial public policy
‘emergency in Puerto Rico, including:
A. Non-Existent Pole Attachment Agreements and Fee Enforcement,
B. Attachment Transfer Cost Allocations and New Attachments,
C. Unreported Attachments, and
D. Facilities in Disuse.
‘The NET understands that clear guidelines for pole attachments are essential, The lack
thereof presents a clear threat to the public infrastructure and impairs government efforts
to modernize and harden the public infrastructure that delivers essential services to the
public. One of the main objectives of the NET is to encourage capital investment in the
development of telecommunications infrastructure, ensuring the availability of the widest
range of competitive possibilities in the supply of telecommunications services and facilities.
The NET promotes providing access to telecommunications services to all consumers
throughout the island, comparable to those provided in urban areas, including low-income
consumers and those residing in rural areas or in areas where access to such services is
expensive. As the main promoter of investment in telecommunication infrastructure and as
guarantors of the enjoyment of telecommunications service to all residents of Puerto Rico
the NET will intervene for the benefit of all parties. Ky ONG
+ Puerto Rico Telecommunications Act, Act No. 213 of September 12, 1996, 27 L.P.R.A.
227 LPRA,§ 269(8) NET-2024-A.0001,
20240627 ERO
Pig.2 de 18,
For these reasons, the NET is compelled to intervene to promote the public interest and
protect critical infrastructure in Puerto Rico, including advancing the utilization of all the
federal funds available for telecommunications projects in Puerto Rico.
Therefore, in accordance with applicable law and the authority granted to the NET, we
hereby address these issues in this Emergency Order and establish a schedule for an
adjudicatory proceeding to address and resolve any remaining T&D pole attachment issues.
A. Non-Existent Pole Attachment Agreements and Fee Enforcement.
Despite managing PREPA’s T&D infrastructure for three years, LUMA reports the absence of
pole attachment agreements with Telecommunications, Cable, and Internet Service
Companies (the “Providers”), and that negotiations to enter agreements have consistently
failed. LUMA further reported that many Providers are making unauthorized attachments
to poles “in violation of [electrical safety] standards” *, which “poses safety risks to LUMA’s
employees and to the public, as well as deteriorates the resilience and reliability of electrical
service.” Without active or coherent pole attachment agreements, LUMA cannot efficiently
enforce safety standards, leading to potential safety hazards, which are causing a public
policy emergency in Puerto Rico.
The ability to assess a fee to Providers for the attachment of cables and equipment on a
government-owned T&D pole is authorized and regulated by the NET. NET regulations
require that any Provider with a T&D attachment on publicly owned property must pay an
attachment fee.
Pole attachment fees are authorized by local, state, and federal law and are assessed across
the country. Such fees applied in Puerto Rico and based on local data will serve as a fair cost
sharing mechanism to ensure T&D infrastructure remains available for responsible
Providers seeking to attach their networks to said infrastructure. Consequently, this
Emergency Order hereby establishes the terms and conditions for the collection and
enforcement of pole attachment fees for FY2024 and prospectively for all Providers’ cables
and equipment attached to publicly owned T&D poles. Moreover, the NET will require,
pursuant to Puerto Rico statute, that Providers be certified or registered with the NET to
be able to have third-party pole attachments on government-owned T&D poles.”
B, Attachment Transfer Cost Allocations and New Attachments.
1. Transfer Costs.
‘The Federal Emergency Management Agency ("FEMA") has approved upwards of $12 billion
in funding to harden and repair T&D infrastructure damaged by Hurricanes Irma and Maria,
and other natural disasters in Puerto Rico. A significant portion of these funds has been
allocated to replace thousands of T&D poles across Puerto Rico (“FEMA-Funded Poles”)
Additionally, LUMA has been replacing damaged or failing T&D poles (“LUMA Replacement
Poles”) (FEMA-Funded Poles and LUMA Replacement Poles are collectively referred to as
“Replacement Poles"). The timely installation of Replacement Poles is crucial for enhancing
the resilience of Puerto Rico’s electrical and communications grid.
However, substantial delays have emerged regarding the transfer of Providers’ attachments
to Replacement Poles. Disputes between LUMA and Providers have arisen, primarily
concerning the costs and workforce required to transfer existing pole attachments over to
+See Luma Monthly Operations Report for January 2024 at 10-11 (February 14, 2024).
td.
51 fie
627 LPRA. § 269(g) and 47 USC.§ 224(c)
7727 LPRA § 269(g). NET-2024-PA-0001
120240627 ERO
Pig. 3 de 18
Replacement Poles. These disputes may impede timely reimbursement of costs associated
with FEMA-Funded Poles, and potentially setting back efforts to implement Puerto Rico's
broadband projects under local and federal funding like: Uniendo a Puerto Rico Fund, Puerto
Rico Broadband Infrastructure Fund, Broadband Equity, Access & Deployment Program,
Digital Equity, Middle Mile Broadband Infrastructure, Capital Projects Fund, Reconnect
Program and others.
According to available information, LUMA has notified Providers of planned pole
replacements, aiming to facilitate proper arrangement for attachment relocation to
Replacement Poles. However, Providers have refused to comply with LUMA’s requests and
declined to perform the work and/or bear the costs associated with relocating their
attachments claiming such costs should be borne, by LUMA, through FEMA funds. To
mitigate the economic impact of relocating attachments, the Government of Puerto Rico,
through the Central Office of Recovery, Reconstruction and Resiliency (“COR3"), requested
FEMA to classify pole attachment relocations as eligible for FEMA funds. Unfortunately,
FEMA denied this request and indicated that no additional funds will be awarded for
attachment relocations.
‘The NET understands that the deployment of the FEMA reconstruction funding is expected
to span multiple years. Without clear guidelines, the controversy surrounding third-party
attachments is likely to persist. This presents a clear threat to the public infrastructure and
impairs government efforts to modernize and harden said infrastructure and deliver
essential services to the public. Moreover, this dispute may jeopardize Puerto Rico's ability
to receive federal funding in the future. The NET is compelled to intervene to promote the
public interest and protect critical infrastructure in Puerto Rico. Failure to address this
controversy could impact the electric grid reconstruction and jeopardize the utilization of
funds available for telecommunication projects under the Puerto Rico Broadband Program
("PRBP”).
Nevertheless, the NET must resolve the underlying issue necessitating the collaboration
between LUMA and the Providers. LUMA and the Providers bear responsibility for resolving
this controversy, with each playing a pivotal role in its resolution. The PRBP has expressed
their intention to develop guidelines for Providers to access funds for the purpose of
mitigating costs to transfer attachments.
Recognizing the urgency to resolve these disputes the NET DEEMS it a public policy
emergency that requires NET intervention. The NET acknowledges the unique challenges
posed by this situation, since relocating thousands of attachments from numerous Providers
in a short time frame presents a logistical and a budgetary challenge. In many pole
replacement cases Providers have failed to transfer their equipment to Replacement Poles,
in other cases LUMA has completed the transfer without provider cooperation. Under these
circumstances many poles have been capped or left in place with no LUMA facilities attached
and remain adjacent to the Replacement Pole. This practice is unacceptable, is a public
nuisance, impairs public safety, and, in some cases, affects the full reimbursement of the
FEMA-Funded Poles.
‘Therefore, the NET DETERMINES that a balanced approach is necessary to address
equipment transfers and allocate responsibilities to both LUMA and the Providers. As such,
the NET ORDERS Providers with attachments on: (i) poles that have been capped or, (ii)
poles from which LUMA has removed its facilities, to immediately start transferring their
equipment to newly installed Replacement Poles.
Regarding LUMA, it must remain compliant with its O&M Agreement and in accordance with
the O&M Agreement, LUMA shall pursue operational efficiency while ensuring safeand
reliable operation of the T&D System. After a thorough review of the O&M Agreement?»
NET DETERMINES that prospectively, for all Replacement Poles installed ‘after this” \
Emergency Order, LUMA shall within reasonable bounds (i
8 See. O&M Agreement, Annex IX. INET-2024-PA.0001
20240627 ERO
Pag. 4 de 18
possible liability concerns) perform the transfer work and bear all costs associated with
transferring Provider's property from existing T&D infrastructure to Replacement Poles,
LUMA shall inform Providers of the transfer progress and use this opportunity to document
the attachments on the Replacement Poles and ensure all attachers are in compliance.
In instances where the transfer work is complex and highly technical (eg. relocating power
supplies, small cell antennas, cable risers, etc.) LUMA may petition the NET, on a case-by-
case basis, that Providers perform the transfer work and bear transfer costs directly. The
NET will evaluate LUMA’s request and, in its sole discretion, determine whether the
applicable Provider(s) shall perform the work inclusive of transfer costs.
Moreover, within ten (10) days of the date of this Emergency Order, LUMA is ORDERED to
provide the NET, and Providers, a comprehensive list of Replacement Poles, to date,
indicating location information and attachment quantity and status. Providers shall: (i)
identify their attachments, (ii) coordinate with LUMA and (iii) successfully transfer their
equipment to newly installed Replacement Poles within sixty (60) days of this order. This
will enable LUMA to remove capped poles. Failure to comply with the requirements of
this Order may result in the NET imposing maximum penalties, to the full extent
permitted by law, including a twenty-five thousand dollar fine ($25,000), per
violation, per year.
‘The NET DEEMS the current situation to be a unique emergency resulting from multiple
natural disasters. The transfer of telecommunications cables and other equipment to
Replacement Poles is required as a consequence of the extensive damage inflicted on Puerto
Rico's infrastructure. As mandated by statute and regulation, the NET is responsible for
overseeing the attachment of equipment to publicly owned infrastructure. This oversight
extends to all associated costs including, but not limited to, pole attachment fees, make-ready
costs, and transfer costs.
As such, the NET determines that, under certain circumstances as set forth herein, both
LUMA and the attaching Providers must participate and perform transfer work, using their
resources.
2. New Attachments.
LUMA, has formalized a procedure for Providers to apply for new attachment permits but
has not approved the majority of said attachment permit applications. This overwhelming
amount of non-approval of new attachment applications is hindering and jeopardizing the
utilization of all telecommunications funds available for broadband projects. The non-
approval rate is mostly related to space requirements or pole loading issues that, according
to LUMA, require make-ready work (eg. pole replacement), and also for the entire cost of the
replacement to be assumed by the new attacher.
‘The public policy of the Government of Puerto Rico is to encourage and needs to facilitate
the utilization of strengthened and modernized T&D infrastructure. Ultimately, this protects
the consumers in Puerto Rico by providing more cost-effective alternatives for Providers to
furnish service therefore stabilizing the industry.
The NET makes the following determinations related to new pole attachments:
a. Application Fees.
On November 20, 2023, LUMA began assessing a $95, per pole, fee to review applications
submitted by Providers to attach cable, Internet, and telecommunications equipment onto.
PREPA-owned T&D poles. While the NET recognizes the need for permitting or application’.
fees, and that LUMA is entitled to recover these costs, NET DETERMINES that LUMA’s per >
pole fee is unsubstantiated and LUMA has not shown it to be cost-basedThis practice may
unreasonably delay Puerto Rico's efforts to implement its island-wide broadl ndlprojects.
\
2
\ INeT-2024-Pa-0002,
20240627 ERO
Pag. S de 18
As part of its analysis, NET reviewed previous fee structures used by PREPA for similar
Provider permit or attachment applications. Historically PREPA charged a per application
charge depending on the number of poles included in the application,
The NET hereby DETERMINES that LUMA is entitled to recover the full amount of the costs
incurred in processing any application, but the application fee must be per application,
not per pole. Accordingly, the NET ORDERS LUMA to cease its $95 per pole application
charge upon entry of this Order. Within thirty (30) days of this Order, LUMA shall submit a
proposal to the NET that includes a new permitting or application fee schedule that is
charged per application, not per pole and that is cost based. Upon receipt, the NET shall
review LUMA’s proposal and accept or reject it at its discretion.
b. National Electrical Safety Code (“NESC”) Spacing.
‘The NET is aware that LUMA is denying Provider attachment applications based on NESC
vertical spacing requirements for equipment placed on T&D poles. First and foremost, the
NET strongly supports the NESC standards. The NESC “sets the ground rules and guidelines
for practical safeguarding of utility workers and the public during the installation, operation,
and maintenance of electric supply, communication lines and associated equipment.”? The
NET continues to prioritize NESC safety standards through this Emergency Order and its
regulatory oversight relating to T&D infrastructure.
On vertical spacing issues, NESC § 235(H) provides the following:
H, Vertical clearance and spacing between communication conductors, wires, and
cables in the communication space.
1. The vertical spacing at the supporting structure, between messengers
supporting communication cables should not be less than 12 in (300mm)
except by agreement between the parties involved including the pole
owner(s).19
NESC § 235(H) acknowledges that, in some instances, the vertical spacing between
communications equipment ona T&D pole can be less than 12 inches. In such circumstances,
the NESC allows LUMA and the Providers to enter into agreements to safely reduce the 12-
inch spacing requirement. Itis the NET’s understanding that LUMA has not yet attempted to
enter into agreement with any Provider relating to narrowing the vertical spacing
requirement set forth in NESC § 235(H). To maximize the use of the available
communications space the NET ORDERS LUMA and the Providers to incorporate six-inch
spacing into any attachment agreements to better utilize the available communications
space of the T&D Poles, subject to case-by-case review and adherence to applicable safety
standards,
¢. Pre-existing Violations and Make Ready Costs
Puerto Rico’s electrical grid is an extremely complex system, and in many areas it is outdated
and has suffered from lack of maintenance. With natural disasters these issues have become
even more relevant and the need for pole inspections and replacements is essential to the
hardening necessary for the Puerto Rico electric grid to be more resilient and withstand
future natural disasters. Under certain extreme conditions (ie, hurricane force winds) some
existing poles do not comply with applicable construction and safety standards, regardless
of new attachment installations. In which case, these poles shall be identified by LUMA as.
having pre-existing conditions that would cause pole loading analysis for new attachments
MONTERO
to fail. ES ey
BY
i es y NS \
° Institute of Electrical and Electronics Engineers ("IEEE") (2024), standardsieesorg/products-
programs/nesc/. {a/
1of
2 National Electrical Safety Code § 235(H) (Clearance for wires, conductors, or cables arvied on the a
supporting structure) (2023) (emphasis added) y NET-2024-PA-0001,
20240627 ERO
Pig. 6de 18
LUMA continues assessing new attachment applications in some instances, when pole
loading analysis fails, new attachment permit applications are not approved or approved
contingent on make-ready works (that could require entire pole replacement). These works
would be performed by LUMA and billed to the new attacher. The NET CLARIFIES that new
attachers shall only be responsible for actual costs incurred to accommodate their new
attachment.
New attachers are not responsible for the costs associated with bringing poles into
compliance with current safety and/or pole owner construction standards, if said poles are
already out of compliance. The new attachment might lead to the correction of pre-existing
violations, but if it is the pre-existing violation that triggers modifications necessary for
compliance the attacher is not responsible for those costs. Holding new attachers liable for
pre-existing conditions discourages deployment and encourages unauthorized attachments.
Make-Ready costs associated with the installation of new attachments on existing T&D poles
shall be limited to those NECESSITATED SOLELY as a direct consequence of the new
attachment request. Under pole replacement scenarios, parties that will benefit from said
replacement (LUMA included) shall share costs proportionally. Accordingly, the NET
ORDERS LUMA to submit all pole attachment applications with non-approvals and disputed
make-ready costs to the NET for review.
C. Unreported Attachments.
LUMA has acknowledged the existence of a significant number of unreported attachments
on public infrastructure.!? An attachment is considered unreported if the attaching entity
falls into one of two categories: (i) unknown provider (i.e, never entered into a third-party
attachment agreement with the electric grid operator) or (ii) known Provider that has
installed new attachments but has failed to complete the attachment authorization process.
In both cases, the attachers are evading payment of any attachment fee for using T&D
infrastructure. Moreover, they are causing harm to responsible Providers seeking to
exercise their right to attach their networks to the T&D infrastructure. Additionally, the NET
shares LUMA’s concerns that unreported attachments could pose substantial safety risks and
may severely compromise the reliability of Puerto Rico’s electrical telecommunications and
cable networks.
Inlight of these concerns, the NET takes action in this Emergency Order to identify all entities
with unreported attachments ("Unreported Attachers"). ‘The NET DETERMINES that all
Unreported Attachers must (i) identify themselves to both the NET and LUMA, (ii) register
and obtain certification with the NET and (iii) adhere to all requirements outlined in this
Emergency Order and applicable law. Failure to comply with applicable law or the
requirements of this Order may result in the NET imposing maximum penalties on the
Unreported Attachers to the full extent permitted by law, including a twenty-five
thousand dollar fine ($25,000), per violation, per year.
D. Fac
ies in Disuse.
‘There are numerous instances where cables and equipment are either non-functional or in
a state of disuse. Such cables and equipment occupy valuable space, hindering the ability of
other companies to attach equipment or expand services. Moreover, disused cables and
equipment can pose a substantial public safety hazard and may contribute to a decrease in
surrounding property values by virtue of their unsightliness. To address this issue, this
Emergency Order mandates all attaching Providers as well as other relevant companies to
submit an inventory assessment. This assessment shall include the location of all)poles in
use and a comprehensive listing of all equipment, regardless of its current, spesaiioral status. a
LF) NY
The NET DETERMINES that all Providers and Unreported Attachers must (i) identify all \2,\
cables and equipment in disuse, (if) formulate a plan to remove the cables in disuse, and (ii) =)
4,
1 See Luma Monthly Operations Report for January 2024 at 10-11 (February 14, 2024). \ NET-2024-Pa-0001
20740627 ERO
Pig.7 de 18
implement the plan to remove cables and equipment in disuse within 90 days of this Order.
Failure to comply with the requirements of this Order may result in the NET imposing
maximum penalties, to the full extent permitted by law, including a twenty-five
thousand dollar ($25,000) fine, per violation.
I LEGAL AUTHORITY
The Communications Act of 1934 established the Federal Communications Commission
(“FCC”) as the independent agency responsible for the regulation of interstate and foreign
communication by radio, television, wire, and satellite. According to this Act, “the [FCC] shall
regulate the rates, terms and conditions for pole attachments’ for poles not owned by any
state.12 However, this section does not apply “for pole attachments in any case where such
matters are regulated by a State”.!3
In 1996, Act 213 created the NET to regulate telecommunications services in Puerto Rico and
provide the compliance and administration of said act.!* Act 213 grants the NET “primary
jurisdiction over all telecommunications services and over all those persons who render
these services in ... Puerto Rico, and over any person with a direct or indirect interest in said
services or companies."!* Furthermore, the NET has all “implicit or incidental powers that
are pertinent and necessary to put into effect to carry out, perform and exercise all the
abovementioned powers...”.16
One of the main purposes of the NET is to encourage capital investment in the development
of telecommunications infrastructure, ensuring the availability of the widest range of
competitive possibilities in the supply of telecommunications services and facilities, as well
as promoting interconnection and interoperability among telecommunications companies.
‘As the main promoter of investment in infrastructure development and as guarantors of the
enjoyment of telecommunications service to all residents of Puerto Rico, the NET promotes
providing access to telecommunications services, reasonably comparable to those provided
in urban areas, to all consumers throughout the island, including low-income consumers and
those residing in rural areas or in areas where access to such services is expensive
Puerto Rico has enacted a law to regulate the terms and conditions for the use of public
property for telecommunications purposes. The NET is tasked with regulating and
supervising all pole attachment issues involving publicly owned poles.!7 NET Regulation No.
9090 of May 10, 2019, titled Regulation for Access to Public Property for Telecommunications,
Information and Pay Television Services (“Reg. 9090"), establishes procedures when a pole
attachment complaint is received by the NET. However, those provisions may be
“supplemented by the provisions of... other regulations in force adopted by the [NET].”"© For
example, applicable provisions of NET Regulation No. 7848 of April 28, 2010, titled General
Rules of Practice and Procedure (“Reg. 7848”) “shall apply [to the NET’s pole attachment
jurisdiction] in a supplementary manner.”!9
Reg. 7848 authorizes the NET to initiate an adjudicatory proceeding “on its own initiative ...
in relation to any matter over which it has jurisdiction and which it deems relevant to its
WAT USC § 224(b).
31d. §224(0)
M27 LPRA.§ 265, et seq.
127 LPRA.§ 267(¢). —
Zgnunicagn
COMUNICAC
'27 LPRA.§ 267(0); see also Claro TV and Junta Regl. Tel. . One Link, 179 [Link].177, 194 (BR.2010), TN
[Sf No
Y27LPRA.§ 269(9) he \
an ae ns (a >
1d, R22. \e\
AN NET-2024-Pa-0001,
20240627 ERO
Pig. 8de 18
obligations and responsibilities under its organic law or special laws.” In case of an
emergency, “the [NET] may use emergency adjudicative procedures, including the issuance
of any interim remedy, in a situation where there is an imminent danger to public health,
safety, or welfare or that requires its immediate action to safeguard its jurisdiction or achieve
the purpose of Act 213."24 If the NET determines to issue such order, the “interim order or
remedy shall contain a concise statement of the findings of fact, conclusions of law, and
public policy reasons justifying the agency's decision to take specific action.”22. In addition,
the order must “contain the date, time and place for the holding of an administrative hearing
or any other proceeding that would have been required in the absence of imminent danger
and shall warn the affected party of the reconsideration mechanism."®? Such an order shall
become effective immediately.
Pursuant to the authority granted to the NET by Puerto Rico statutes and regulations, and in
compliance with applicable federal law, the NET hereby issues the following Emergency
Order.
tl EMERGENCY ORDER
‘The NET hereby ORDERS the following:
A. Inventory Assessment.
Within sixty (60) days of this Order, all attaching Providers and Unreported Attachers are
ORDERED to produce, based on current and available records, a true and correct inventory
of (i) the type and routing of all cables and equipment attached to T&D poles (including
cables and equipment in disuse to be identified as such), and (ii) the quantity and location of.
all attachments to public T&D poles (the “Inventory Assessment”). Moreover, the Inventory
Assessment must include a detailed Statement of Public Safety that identifies a corrective
plan for all pole attachments that do not comply with applicable provisions of the National
Electrical Safety Code (“NESC"). The Inventory Assessment must be submitted in a
Geographic Information System ("GIS") mapping format. The Inventory Assessment must be
submitted to the NET, by each Provider, with a certified declaration, under oath, stating that
it includes all the information available and that it is a true and correct inventory of all its
cables, facilities and equipment.
B. _ Interim Pole Attachment Fee.
The NET ORDERS that all Providers and other companies in Puerto Rico with cable, Internet,
or telecommunications attachments affixed to any T&D poles owned by PREPA and managed
by LUMA must pay an annual attachment fee. All Providers and any other company with
attachments must pay attachment fees in accordance with the following terms and
conditions. The NET reminds LUMA and all Unreported Attachers that any attaching
Provider must be certified and registered with the NET in order for them to be able to have
third-party pole attachments on government-owned T&D poles.
1. The NET ESTABLISHES an attachment fee of $8.65 per attachment for
FY2024 (“Interim Attachment Fee”),
2. All Providers and Unreported Attachers with attachments on PREPA-owned
‘T&D poles are ORDERED to make payment of the Interim Attachment Fee to
LUMA (based on the most recent number of known attachments and
thereafter adjusted based on the certified Inventory Assessment) in
Installment Payments in accordance with the Schedule specified_below.
“QMUNICAC™
Seer eee Je oe.
2 Reg. 7848, R. 3.1 AE ON
211d, R 38.1.
21d,R383.
2d NET-2024-Pa.0001,
20240627 ERO
Pig. 9 de 18
Payment of the Interim Attachment Fee must occur, regardless of having
received an invoice from LUMA, with the First Installment due on or before
August 30, 2024. The First Installment shall be in the amount of 10% of the
assessed Interim Attachment Fee, with all remaining Installment Payments to
be in the amount of 30% of the assessed Interim Attachment Fee, accordingly.
All Provider and Unreported Attacher Installment Payments for the Interim
Attachment Fee must be made in accordance with the following Schedule:
Schedule:
Installment Payments Due Date
First Installment (10%) August 30, 2024
Second Installment (30%) September 30,2024
Third Installment (30%) _ October 31, 2024
Final Installment (30%) December 31, 2025
The Interim Attachment Fee applies to FY2024 only. As discussed herein, the
NET hereby schedules an adjudicatory proceeding to assess attachment
variables and set any adjusted attachment rate for FY2024, FY2025 and any
applicable succeeding years.
€ Transfer Cost Allocations,
1. LUMA Responsibilities Relating to Prospective Transfers.
‘The NET ORDERS that LUMA is the primary entity responsible for executing and completing,
at its own expense and using all necessary resources, all transfers of pole attachment
equipment from existing T&D poles to any newly constructed Replacement Poles. LUMA
shall thoroughly document all aspects of these pole attachment transfers (ie, cost, quantity,
location, Provider). LUMA shall inform Providers of the transfer progress and use this
opportunity to document the attachments on the Replacement Poles.
LUMA may recover said transfer expenses exclusively through a transfer-cost component to
the prospective attachment fees (ie, starting with FY2025 Attachment Fee). Moreover,
pole attachment related costs SHALL NOT be passed on to electric energy consumers
by LUMA, including but not limited to surcharges, fees, or rate increases.
Nothing in this section precludes a Provider from independently transferring at its cost and
expense its own equipment and facilities to any pole or Replacement Pole.
In the event LUMA deems any transfer-work as exceptionally complex, LUMA shall notify the
NET and Providers, based on the NET Reg. 9090 Rule 22, on a case-by-case basis, and request
NET evaluation as to whether a particular transfer should be executed by Providers. Such
petition for NET evaluation must be factually specific and not global in nature. If the NET, in
its discretion, concludes that a Provider must implement the transfer, then the NET will
notify LUMA, and the Provider of its determination and the Provider shall use its resources
for such transfer.
2. Provider Responsibilities Relating to Transfers Involving
Previously Installed Replacement Poles.
To facilitate all attachment transfers, within ten (10) days from this Emergency Order,
LUMA is ORDERED to provide the NET, and Providers, a comprehensive list of Replacement
Poles, to date, indicating source of funding, location information, attachment quantityand~
status. | Bia OU
To facilitate the reimbursement of FEMA funds, in the case of FEMA-Funded Poles thathave | |
already been installed by the notification date of this Emergency Order, th DERS all
Providers to execute and complete the transfer oftheir pole attachments eu sixty “y NET-2024-PA.0001
20240627 ERO
Pig, 10 de 18
days of this Emergency Order. In the case of the remaining Replacement Poles that have
been installed by the notification date of this Emergency Order, the NET ORDERS all
Providers to execute and complete the transfer of their pole attachments within one
hundred and twenty (120) days. Each Provider must: ({) identify their attachments, (ii)
coordinate with LUMA and (iii) successfully transfer their equipment to the Replacement
Poles so that LUMA to be able to remove the old pole, Failure to comply with the
requirements of this Order may result in the NET imposing maximum penalties, to the
full extent permitted by law, including a twenty-five thousand dollar ($25,000) fine,
per violation.
3. Other Requirements.
Inany event, in the process of transferring or modifying Provider equipment and lines to any
Replacement Pole, LUMA and Providers shall not leave any equipment or lines on the ground
or otherwise leave such equipment and lines in any state of disuse as would constitute a
public nuisance or public safety hazard. In case of an emergency, LUMA shall give prompt
notice to the Providers’ Network Operations Centers of any such impacted equipment and
facilities.
D. _ Pre-existing Violations and Make-Ready Costs.
‘The NET ORDERS that Providers are not responsible for the costs associated with bringing
poles into compliance with current safety or pole owner construction standards if said poles
are already out of compliance. The new attachment might lead to the correction of pre-
existing violations, but if tis the pre-existing violation that triggers modifications necessary
for compliance, the attacher shall not be responsible for those costs. Make-ready costs
associated with the installation of new attachments on existing T&D poles shall be limited to
those NECESSITATED SOLELY as a direct consequence of the new attachment request.
Under pole replacement scenarios, parties that will benefit from said replacement (LUMA
included) shall share costs proportionally. LUMA shall fund said costs exclusively through
its operational budget.
E. Unreported Attachers.
‘The NET ORDERS all Unreported Attachers to immediately: (i) identify themselves to both
the NET and LUMA, (ii) obtain any required registration or certification with the NET to
attach cable, Internet, or telecommunications equipment on public T&D poles, and (iii)
otherwise adhere to all requirements outlined in this Emergency Order, as well as applicable
law. Failure to comply with any requirements may result in the NET imposing
maximum penalties on the Unreported Attachers to the full extent permitted by law,
including a twenty-five thousand dollar ($25,000) fine, per violation, per year.
FE
‘The NET ORDERS all Providers and Unreported Attachers to: (i) identify all cables and
equipment in disuse, (ii) formulate a plan to remove the cables and equipment in disuse, and
(iii) implement the plan to remove cables and equipment in disuse within ninety (90) days
of this Order. Failure to comply with the requirements of this Order may result in the
NET imposing maximum penalties on the Provider to the full extent permitted by law,
including a twenty-five thousand dollar fine ($25,000), per violation.
All Unreported Attachers are required to comply with this Emergency Order, Additionally,
any Provider or Unreported Attacher may submit a report explaining exigent. pmuponal
needs or circumstances, or circumstances where multiple occupation of a poleby Providers
does not allow further attachments due to structural or spacing considerations. Pa
Providers and Unreported Attachers are encouraged to identify to the NET any alleged NESC
violations or cables in disuse that are hindering development and deploym papeggrbond \=
ona per-pole basis. NBT-2024-Pa-0001,
20240627 ERO
11de18
G. Attachment Application Fees.
‘The NET ORDERS LUMA to cease charging a $95 per pole application fee to Providers
seeking to place new attachments on T&D poles.
Within thirty (30) days of this Order, LUMA is ORDERED to submit a proposal to the NET
that includes a new permitting or application fee schedule that is cost based and charged per
application, not per pole. The NET, at its discretion, shall approve or deny LUMA’s proposal.
LUMA shall not assess any application or permitting fee until such fee is approved by the
NET.
Attachment Application Non-approvals or Denials.
Pursuant to Rule 12 of Reg. 9090 and Act 80-2017, Puerto Rico law establishes the
presumption that LUMA shall approve Provider applications to attach cable, Internet, and
telecommunications onto publicly owned T&D poles.
Accordingly, LUMA shall not deny any such application until such denial is reviewed by the
NET. The NET ORDERS LUMA to submit to the NET all pole attachment applications with
non-approvals and/or Make-Ready costs to the NET for review. LUMA shall submit said
applications within thirty (30) days of the Providers’ submission to LUMA. No application
denial shall go into effect until such denial is reviewed by the NET, at its discretion.
1. __NESC Spacing Requirement.
LUMA and all attaching Providers are ORDERED to immediately incorporate a six-inch
spacing into any attachment agreements, as allowed by NESC § 235(H), to better utilize the
available communications space of the T&D Poles, subject to case-by-case review and
adherence to applicable safety standards.
J. Adjudicatory Proceeding.
In accordance with Rule 38.3 of NET Regulation 7848, the NET hereby ORDERS that a two-
week adjudicatory proceeding be scheduled beginning on November 11, 2024 to resolve all
remaining pole attachment issues, including but not limited to (i) determining the
attachment fee for FY2025, including enforcement of pole attachment fees for FY2024,
FY2025, and beyond, (ii) the entering into of pole attachment agreements between LUMA
and Providers, (iii) new attachment assessment fees (i.e, application fees), (iv) consideration
of transfer costs to Replacement Poles and and other make-ready costs, (v) LUMA’s
application of NESC standards relating to Provider attachments and vertical spacing
considerations, (vi) determination of potential amounts owed for unpaid pole attachment
fees between 2017 and 2023, and (vii) for any other purposes reasonably connected with
the use of public T&D infrastructure by Providers in Puerto Rico,
The NET will issue a Scheduling Order for this adjudicatory proceeding within sixty (60) days
after the issuance of this Emergency Order.
‘The NET ORDERS the participation of LUMA, all Providers, and all Unreported Attachers at
this proceeding. The hearing will determine any adjusted pole attachment rates for FY2025
and beyond (“Adjusted Attachment Fee”) and any required enforcement terms thereof.
At this proceeding, the NET will attempt to mediate the adoption of pole attachment
agreements between LUMA and any attaching Provider or other company. Additionally, the
NET may hear testimony and review any remainingissues, including but notlimited to costs
of equipment transfer to Replacement Poles, LUMA's assessment fees, and LUMA'S”,
application of the NESC relating to pole attachments and spacing considerations on TED .
poles. NET-2024-PA.0001
120240627 ERO
Pig, 12 do 18
If LUMA and any Provider or other company cannot come to agreement on any material
terms and conditions relating to pole attachments in pole attachment agreements, the NET
is prepared to adopta final order to resolve all issues. This is necessary to correct the current
situation adversely affecting public health, safety, and welfare in Puerto Rico, and to remove
barriers to the Government's deployment of funding for broadband infrastructure and the
provision of essential broadband services.
K. Confidentiality.
Itis ORDERED that all documents, inventories, payments, or other information required by
this Emergency Order, which are clearly labeled as Confidential, shall remain Confidential to
the extent permitted by law.
L. Reconsideration.
Provided, that any party adversely affected by this Resolution and Order may file a motion
for reconsideration with the Secretary of the Puerto Rico Telecommunications Bureau
(NET), within a term of twenty (20) days, counted from the filing on file of the notice of this
Order. The petitioning party shall send a copy of such motion, by mail, to the parties that
have intervened in the proceedings of the case.
‘The NET shall consider such motion for reconsideration within fifteen (15) days of its filing.
If it rejects it outright or fails to act within fifteen (15) days, the thirty (30) day term to
request administrative or judicial review shall begin to run from the date of notice of such
denial or from the expiration of such fifteen (15) days, as the case may be. If any
determination is made in its consideration, the term to request review shall begin to run
from the date on which a copy of the notice of the resolution or order of the NET definitively
resolving the motion is filed in the files. Such resolution or order must be issued and filed
within ninety (90) days following the filing of the motion for reconsideration. If the NET
grants the motion for reconsideration, but fails to take any action in relation to said motion
within ninety (90) days after it has been filed, it shall lose jurisdiction over the same and the
term to request administrative and judicial review to the Public Service Regulatory Board or
to the Court of Appeals, respectively, shall begin to run as of the expiration of said term of
ninety (90) days, unless the agency, for just cause and within said ninety (90) days, extends
the term to resolve said motion, respectively, shall begin to run as of the expiration of said
ninety (90) day term, unless the agency, for just cause and within said ninety (90) days,
extends the term to resolve for a period that shall not exceed an additional thirty (30) days.
However, the NET may accept or make a determination on a timely filed motion for
reconsideration, even after fifteen (15) days from the filing thereof, provided that the term
for administrative or judicial review has not elapsed and no such motion for review has been
filed. The NET may also reconsider, on its own initiative, this Resolution and Order, as long
as the term for administrative or judicial review has not elapsed and no such review has been
filed.
If the party adversely affected by this final order or resolution chooses not to request its
reconsideration, pursuant to the provisions of Section 4.2 of the Uniform Administrative
Procedure Act of the Government of Puerto Rico (Act 38-2017), it may file a request for
review to the Public Service Regulatory Board or to the Puerto Rico Court of Appeals, within
a term of thirty (30) days, counted from the date of the filing in the file of the copy of the
notice of the final order or resolution of the NET. The party shall give notice of the filing of
the request for review to the NET and to all parties within the term to request such review.
Notice may be given by mail. Provided that, ifthe date of filing of the copy of the notice of
the final order or determination of the NET is different from the date of the deposit faithe
mail of such notice, the thirty (30) day period for requesting adiminisralye op satel ee reac \
shall be calculated from the date of the deposit in the mail S\ NET-2024-PA.0001
20240627 ERO
Pig. 13 de 18
Itis SO ORDERED.
Publish and notify.
Férdinand™s Ramos Soeg
Associate Comm orier
Interim President
(vacant)
to-Garcia Associate Commissioner
Associate Commissioner
CERTIFICATION
I certify the following: (1) This Resolution and Order was agreed upon by the majority of the
Members of the Telecommunications Bureau on June 27, 2024, (2) On June 2¥, 2024, this
Resolution and Order was publicly recorded on file at the Bureau, and (3) A copy of this
Resolution and Order was noticed to:
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