INTRODUCTION
The initial pages of this paper will provide a detailed explanation of “make ready – what it is and how it evolved. If you’re well acquainted with the concept, you may wish to jump forward to the section of the paper that deals with the development of a Project Execution Plan” for a make ready project. That topic is under the heading of “MOP FOR ROUTE MAPPING, MAKE READY AND POLE APPLICATIONS”.
The term “make ready” refers to attaching cables to utility poles in a manner such that the separation between new cables and existing cables is in accordance with the National Electrical Safety Code (NESC). The majority of the utility poles we see along roads and in back yards belong to two companies – the incumbent local exchange carrier (ILEC), commonly known as the telephone company, and the local power/electric company. The companies that wish to attach to the poles are third-party companies, mostly cable TV companies, competitive local exchange carriers (CLEC), or internet service providers (ISP). These are broadband service providers and the majority of the cables they wish to attach to poles these days are fiber optic cables.
The telephone and electric companies own the overwhelming majority of the poles we see along the streets and in back yards. Many of these poles have been in “service” for decades meaning that they were placed before or during the first cable TV build-outs of the 1980’s. Utility company technicians did not anticipate the number of parties who would want to attach to the poles when they selected the “size” of the poles to be placed. Utility poles generally range in height between 25 and 55 feet. The diameter (Class) of the poles vary according the length and designed load of equipment that’s planned to be attached to the pole (Pole Loading Analysis). Depending on their engineering practices, utility companies may, or may not consider the need for taller poles in anticipation of potential third party applications for attachment rights.
CABLE SEPARATION REQUIREMENTS
The required height of a utility pole is dictated by what’s attached to it. As mentioned in the Introduction, the overriding specification for the required separation of cables and equipment on poles is the National Electrical Safety Code (NESC). The NESC dictates what the separation between cables and equipment primarily based on the voltage “carried” by the cables – generally, the lower the voltage, the less separation is required.
“Fig. 235-10. Example of vertical clearance between joint-use (supply and communication) conductors (Rule 235C).”
Excerpt From: David Marne. “National Electrical Safety Code (NESC) 2012 Handbook.” iBooks. https://itun.es/us/Sw-_F.l
The telephone copper cables, the cable TV coax cables, and the CLEC, cable TV, and ISP fiber optic cables are low voltage and are attached at the lowest heights on the utility poles and with the least separation requirement – generally 12” vertical separation. The electric power cables and equipment are generally located a minimum of 40” above communication cables. The NESC contains many other separation requirements including the distance between cables at “mid-span” between poles. Additionally, the NESC specifies the required height of cables above roadways, highways, driveways, railroads, navigable waterways, and other similar structures. See fig. 232-4 from the NESC below for an example.
“Fig. 232-4. Example of how clearance values are determined (Rule 232B).”
Excerpt From: David Marne. “National Electrical Safety Code (NESC) 2012 Handbook.” iBooks. https://itun.es/us/Sw-_F.l
How do third party pole attachment companies know if there’s enough room on the poles to attach their cables, and what happens if there isn’t enough room?
NOTE TO READERS: There are hundreds of variants to the process of applying for the right to attach to utility poles and the “make ready” engineering and construction that must precede the issuance of pole attachment permits. In the remainder of this paper I will be describing the generic process based on my decades of experience with numerous utilities, both telephone and power company pole owners.
POLE APPLICATIONS
Before the third party attachers submit applications to the utility companies for a license to attach to their poles, they must first design their route and therefore which poles they need to put their cables on. This document is called a route map or a strand map in cable TV days. A list of the poles being applied for is prepared using the utility company’s specific format(s). There’s no standardization for application formats between telecom and power companies and between states, counties, or municipalities throughout the US. Some attempts are underway to standardize application formats and nomenclature across subsidiary companies both in the power and telecom sector, but these efforts are largely related to standardizing internal database records and facilities management systems. The pole application formats usually have a limited number of spaces on the forms for listing poles, often twenty-five poles per form. The utilities also commonly restrict the number of poles that can be applied for in a time period such as a maximum of 200 pole applications in a calendar month. The utilities also commonly set a minimum time frame for their responses to the applications – commonly 45 to 60 days. Obviously, if a company is planning a large geographical area build-out, these limits will quickly become a bottleneck in their build schedule.
AND THEN, THERE’S MAKE READY…
The term “make ready” is defined in the introduction to this paper. The concept appears to be simple, but the actual procedure is anything but. Generally, the make ready process is led by the telephone company, and there are logical reasons for that procedure. In order to ascertain if there is enough space on the poles for the third parties cable, someone has to go to each pole and measure (literally) the height of each of the existing cables on the poles. The old-fashion method of doing this is with a fiberglass measuring stick that can reach the conductors on the pole and “measure” the height of each cable and piece of equipment. Many attempts have been made over the years to bring a technological improvement to this method, but to date I’ve only seen one automated system that is effective for the replacement of the measuring stick method – that is the ikeGPSÒ 4 system and equipment. I’ll write more on that later in this paper, after I’ve explained the make ready process in greater detail.
After the poles are identified and the applications submitted to the pole owners, the next action will be the initial make ready survey. The route survey may include identifying poles that require make ready, but that would be provided by a subcontractor working for the pole applicant. Therefore, it is likely that a make ready survey will be undertaken by the pole owners, starting with the telephone company staff. The telephone company usually starts the survey because having the communications cables lowered to make room for a new attachment is almost always less expensive than raising power cables and equipment. In some cases, the applicant’s engineering subcontractor may accompany the telephone company engineer on this first pass make ready survey. The applicant and telephone representatives may design a “re-route” in the field if they find difficult make ready situations. The first-pass survey will almost always identify poles where make ready is required, but the communications cables cannot be lowered adequately to provide space for the new cable. These poles are put into a file to be surveyed by the power company engineer to ascertain if the electric cables and/or equipment can be raised sufficiently to provide the needed space on the pole.
The power company engineer may visit the designated poles by his/herself, or may arrange to team up with the telephone company engineer for this third visit to the make ready poles. The power company engineer will make the determination if the electric cables and equipment may be rearranged sufficiently to accommodate the applicant’s new cable. Of course, there will be a handful of locations where no amount of rearranging of the existing communications and power plant can be done to make space for the new cable. In this circumstance, the owner of the pole will undertake the work of replacing the pole with a taller one. Pole replacements are usually expensive and are therefore only considered as a last resort for the company seeking an attachment permit. When the utilities determine that a pole replacement is required, the applicant will in most cases attempt to reroute their cable in an attempt to avoid changing out a pole. Of course, it would be more efficient both in time and dollars to identify the potential pole replacement during the route selection and mapping process and not apply for that pole from the start. While that seems logical it requires that the field technician who does the original route mapping to have adequate knowledge of communications and power outside plant to be able to make the determination about the make ready work requirements on a pole by pole basis. It is unusual for the route mapping field personnel to have that level of knowledge. If the concept of “One Touch Make Ready” (OTMR) were more commonly accepted and practiced, the need for multiple field visits to determine if a pole requires replacement (or even just extensive make ready) would be eliminated during the initial survey. I’ll provide a synopsis including the advantages of using OTMR at appropriate places in this paper.
The poles that are surveyed for make ready work will fall under one of the following categories:
- The pole is “clear”, meaning that there’s adequate room for the new cable to be attached and be in compliance with the NESC.
- The owner of the pole will issue a permit to attach once the fees are paid.
- There is not adequate space (nominally 52”) to attach the new cable in compliance with the NESC, but lowering one or multiple communications cables may be done to provide the space while staying within the specifications.
- In this case, the telephone company will write a work order for their crews to lower their cable(s). The telephone company usually will notify any other communication cable(s) owners who are attached to the pole (by permit) that they will also have to lower their cable(s). These days it is not unusual for there to be as many as ten communications cables attached on both field side and street side of the poles.
- The work orders are issued to the construction department or their approved contractors and the work is scheduled along with the new and routine work in the que.
- There is not adequate space (nominally 52”) to attach the new cable in compliance with the NESC, but a combination of lowering communication cable(s) and raising electric secondaries and related plant (street lights, transformers, neutral cables, etc.) will result in adequate space for the new cable installation.
- The telephone company engineer will notify the power company engineer of poles that fall into this category. A joint field survey will be scheduled for these and the other poles that required electric plant rearrangements. Each party determines what work they will have to perform to jointly “clear” the pole.
- The telephone company will write a work order for their crews to lower their cable(s). The telephone company usually will notify any other communication cable(s) owners who are attached to the pole (by permit) that they will also have to lower their cable(s).
- The power company engineer writes a work order for the electric company’s construction crews or their approved contractor to perform the make ready construction work.
- The utility companies schedule the make ready work along with their new and routine work.
- There is not adequate space (nominally 52”) to attach the new cable in compliance with the NESC, but lowering the communication cable(s) is not an option usually due to ground clearance issues.
- The telephone company engineer will send this pole sheet or format to the power company engineer for field survey and determination if rearranging the electric plant on the pole will provide adequate space for the new cable.
- It’s not uncommon for the telephone company engineer and the power company engineer to perform a joint field survey of poles that require electric plant rearrangements. In rare cases, this joint survey will result in the determination that the pole must be replaced.
- The pole applicant is usually notified when poles are determined to require replacement. In most cases, the pole applicant will go to the field (again) and attempt to find a reroute that will eliminate the time and cost of a replacement.
- The power company engineer writes a work order for the electric company’s construction crews or their approved contractor to perform the make ready construction work.
- There is not adequate space (nominally 52”) to attach the new cable in compliance with the NESC, but a combination of lowering communication cable(s) and raising electric secondaries and related plant (street lights, transformers, neutral cables, etc.) will result in adequate space for the new cable installation.
- The telephone company engineer will notify the power company engineer of poles that fall into this category. A joint field survey will be scheduled for these and the other poles that required electric plant rearrangements. Each party determines what work they will have to perform to jointly “clear” the pole.
- The telephone company will write a work order for their crews to lower their cable(s). The telephone company usually will notify any other communication cable(s) owners who are attached to the pole (by permit) that they will also have to lower their cable(s).
- The power company engineer writes a work order for the electric company’s construction crews or their approved contractor to perform the make ready construction work.
- The utility companies schedule the make ready work along with their new and routine work.
- The worst case scenario as mentioned earlier in this paper is when it is determined that no amount of cable and equipment rearrangements on a pole will provide adequate space for the new cable. This then becomes the dreaded pole replacement. Pole replacements are dreaded because they are expensive and time consuming. A simple pole replacement may cost a couple thousand dollars, but a complicated (and most are) replacement can cost more than thirty thousand dollars. Pole replacements are time consuming for a variety of reasons, not the least of which is the necessity for all of the companies with cables on the pole will be required to detach from the old pole, and reattach to the new pole.
- The process is similar to that described in the above scenarios. No doubt, there will be multiple field trips by all of the parties to evaluate the field situation to determine if replacement is the only option.
- When all options have been investigated and the determination is made that a pole must be replaced, the respective pole owner and respective attachment owners will prepare the necessary work orders and the work is scheduled.
- The requirement for Pole Loading Analysis (PLA) documentation is becoming more common, especially in new pole/pole replacement situations.
At a minimum, there will be two visits to a pole in the process of mapping and applying for attachment permits. At the other extreme, poles that will require replacement may be visited between six to ten times by various groups including the pole owner, the pole applicant, and any/all of the current pole attachers before the work orders are written to perform the work. The delay caused by multiple visits to a pole will in most cases affect the processing of all of the other poles that are in the same group or packet with the pole replacement.
THE TRICKY BITS ABOUT MAKE READY
Even the specifications included in the NESC have local variations, but probably the trickiest bit about make ready is who pays for what parts of the work. When cable TV systems were first starting to be built in the suburbs the telephone and power companies took the attitude that whatever work was required to accommodate the cable TV plant would have to be paid for by the cable TV companies. The cable TV companies quickly pointed out that the telephone and electric cables were, in many places, not installed to NESC specification before cable TV came into the picture. After bouts of niff-nawing the utilities agreed that if they were out of spec themselves, they wouldn’t charge cable TV to “correct” the deficiency during the make ready process. As an example, a pole that has less than 40” separation between the top communications cable and the lowest power secondary will have to be rearranged before cable TV can attach, but the utilities will not charge for the rearrangement(s). The example is simplistic, the reality in these days of 3 to 10 communication company’s cables attached to poles is much more complicated.
The cost of moving cables up or down on a pole isn’t usually daunting, but the cost of replacing a pole to gain additional height is enough to get applicants excited. This is particularly the case when the original owner of the pole being replaced will end up with a brand new, taller pole and have all the cables and equipment transferred at no cost – in some cases.
The logistics of accomplishing make ready engineering and construction evolved primarily based on which utility would do work on the greater percentage of the poles requiring rearrangements, i.e. the telephone company. It made sense therefore for the telephone company to do the initial make ready survey and write the work orders for as many poles as they could clear before bringing the power company into the process. Presumably, after the initial survey, the only poles that will remain to be made ready will be poles that require electrical plant rearrangements.
The telephone companies took the lead in in the make ready process. Of course, the applicant must establish pole ownership during the route survey and submit applications to the appropriate company. The information required on the application forms varies in content and format from company to company. The number of poles that can be listed in an application varies as well, as does the minimum time frame before a response is sent to the applicant. Many pole application forms have a check box where the applicant is required to indicate if make ready work will be required. That means that the company that does the route mapping will also be making some rudimentary determination about make ready. Not what work needs to be done to clear a pole, only that there isn’t sufficient space on the pole today thus supposedly eliminating the need for the telephone company representative from having to survey every pole on the application. The route map field technician needs to “measure” the space between the communication cables and the power cables. Traditionally, this survey work was accomplished by the “stick and wheel” method. The “stick” in this case is a 35-foot collapsible fiber glass measuring ruler that can be extended to measure the attachment heights of the cables on the pole. The “wheel” is a device that resembles the front wheel of a bike, but with a handle attached where the fork would be. This device is pushed along the surface between poles and measures the distance between the poles. This is called the “span distance” and must be included on the route maps that are submitted with the pole applications.
AUTOMATING THE ROUTE MAPPING AND POLE SURVEY WORK
Many attempts to bring automation to the route mapping and pole survey (measuring) work have been made over the years. I have reviewed and tested many of these systems, but I’ve seen only one that I think is viable. That system is the IKE 4 (http://ikegps.com/wp-content/uploads/2016/06/IKEbase-datasheet-160503-forWeb.pdf). I won’t go into detail on the IKE 4 system in this paper. The link to the data sheet is provided for the reader to review if they wish. I have had experience with this system on a number of field projects and found it to be very useful when the equipment is intelligently utilized. A well-crafted and comprehensive Project Execution Plan is essential for success, as it is for any engineering project.
This may be the right place in this paper to make the following statement – computers cannot do make ready. Whether the survey work is done using state of the art equipment such as the IKE 4, or if it’s done with the stick and wheel method, the actual analytical process used in deciding what make ready work is to be done needs to be done by human technicians. I know I’ll get arguments about this statement, but be assured I’ve proven this conclusion on numerous occasions.
ONE TOUCH MAKE READY
There are no national codes or guidelines for make ready. The FCC 11-50 – Implementation of Section 224 of the Act A National Broadband Plan for Our Future – April 2011 contains the section below.
- The record in this proceeding demonstrates that the current framework often results in negotiation processes that may be so prolonged, unpredictable, and costly that they impose unreasonable costs on attachers and may create inefficiencies by deterring market entry.
That wasn’t news in 2011 to people who dealt with make ready going back to the 1970’s. Obviously, there was NOT significant improvement in the process in the five years after the FCC 11-50 because Google Fiber is vigorously attempting to revive the “One Touch Make Ready[1]” (OTMR) concept in the Memphis network buildout. Google Fiber has reached the conclusion that they cannot meet schedules or budgets if they’re required to de make ready in the traditional manner (see “The History of One Touch Make Ready” by the author of this paper).
OTMR is just as logical today as it was when the concept was first conceived. There are no insurmountable challenges in implementing OTMR today in markets such as Memphis. All it will take to implement OTMR is a commitment by all parties that they want to use this method. Then there is the biggest challenge to using OTMR – finding a qualified engineering/construction firm who is acceptable to all parties. Of course, a reasonable and well-designed methodology for payment needs to be created. If the parties agree to the concept, the terms and conditions issues can be resolved.
Obviously, the firm that is selected to lead OTMR is most likely an engineering firm with established credentials. The engineering firm will need to have the services of an equally credible utility construction firm that is acceptable to the power and telephone pole owners, as well as all of the other pole attachers. Again I’ll state that if the parties agree in principal, the logistics can be worked out.
MOP FOR ROUTE MAPPING, MAKE READY AND POLE APPLICATIONS
This Method of Procedure is written such that it can be performed by the “stick and wheel” method or utilizing a GIS-based automated data acquisition tool such as the IKE 4. Where appropriate I’ll make side notes on specific topics.
- Without a doubt, my first and most important recommendation is to prepare a Project Execution Plan (PEP). This should not be a huge document that gets put into a three ring binder and placed on a shelf never to be consulted again during the project. The PEP should be five to ten pages and will cover the major assumptions, processes, and procedures that are anticipated to be a part of the project. The PEP should be given to and reviewed with all of the participants in the project from executive management on down to the field technicians and clerical staff during the project kickoff meeting. The PEP will be an organic document that may change, revised, or added to in the course of the project.
- Do not overlook the need to get specifications and filing instructions from the utility company contacts you’ll be working with.
- Also, be sure to obtain and include the names of all of the other attachers to the poles that will be included in your applications and also how to identify their cables on the poles before starting the survey.
- The headings in the remainder of this section of the paper will likely become the headings to be covered in the PEP.
- Select and procure base maps.
- Most readers will find that either their company or the pole owners will make this decision for them.
- Many route maps are created in Google Earth. GPS files can be overlaid and poles will populate the maps in the proper location.
- Poles in Google Earth maps can be tagged with photo and GIS data files. The IKE 4 system can imbed photo files that include photos of the poles that show all of the cables and plant and includes the heights of each attachment from the ground.
- Conduct a preliminary/exploratory meeting with the poles owners.
- Gather forms, formats, instructions, reference materials, and the names and contact information for the other attachers.
- Review intended survey techniques and deliverables with the utility companies.
- Review the proposed schedule milestones and order of march intended for the build-out.
- How does this preliminary schedule hold up against the availability of the utility company’s resource – both engineering and construction?
- What are the logistics of third party rearrangement requirements?
- Who schedules and coordinates this work?
- Based on the information gathered in number 3 above, prepare a sample deliverable using approximately 10 or 15 poles and run it through the entire submission, make ready survey(s), third party rearrangements, construction and permit issuance process. It is imperative to obtain approval of the sample application as early in the project as possible.
- I have witnessed companies by-passing this critical step in an effort to rush applications into the process only to see them have to do rework in the field and in the office to “correct” future applications.
- To the extent feasible, the sample submission should include as many of the different circumstances as may be encountered in the overall project.
- Use the sample submission for gauging realistic durations for the various tasks in the project’s Work Breakdown Structure.
- Use this information to revise and lock down a baseline schedule. THIS IS AN IMPORTATNT TOOL AND SHOULD NOT BE OVERLOOKED.
- Kickoff Meeting – Preplanning saves a lot of fan cleaning. Gather utility and third part attachers representatives along with the project staff at a project kickoff meeting.
- Present the tactical plan based on route mapping and sample submission processing and request that any potential revisions be discussed and decided before the survey is launched.
- Procedural conflicts that may result in delays and rework should be identified and resolved at the kickoff meeting.
- The baseline schedule for the project must be presented and discussed.
- The methods for gathering and report progress and a schedule for update meetings will be developed and agreed to during the kickoff meeting.
- The Progress, Plans, and Problems (PPP) is one of the best reporting and documenting formats available. See – https://wordpress.com/post/ventureinitiativesllc.wordpress.com/25 .
- Progress tracking and review meeting – These meetings should be held at a maximum interval of two weeks, but weekly is better. Of course, this depends on the size and therefore the duration of the project. The project manager may decide to have a joint project review meeting including the project team and the appropriate utility company representatives. Or, the project manager may hold internal staff review meetings. It’s often best practice to alternate meeting participants, or hold two meetings in each period.
- The throughput or product of the project is pole attachment permits delivered. This is the metric for measuring, tracking and reporting progress and should focus on the speed of throughput, i.e. permits received.
- The stakeholders in make ready projects are usually the management team of the company that is applying to attach to the utility poles. The stakeholders may attend the PPP review meetings, or the project manager may provide them with a redacted report. A one-page report format is ideal for this purpose. There are a number of effective one-page project reporting formats available today, but the one I find most effective and reasonable in the “One Page Project Manager” (OPPM). Here is the link:
- https://oppmi.com
- Based on my decades of experience in the general arena of project management related to engineering and construction projects, I recommend precise and succinct progress reports. The essence of the project’s progress can be communicated to the team with dashboard type reports preferably on a single piece of paper.
- Obviously, the one-page report may be supported by more detailed data and reports, but the “red flag” needs to be communicated to the project team at a high level.
- Solutions to the red flag issues must be addressed immediately. The effects of red flag issues must be integrated into the baseline project schedule as quickly as possible and those effects must be communicated to the project team, including stakeholders at the earliest possible time.
CONCLUSION
My decades of experience in projects that included make ready, but also design/build projects of other types causes me wonder why the lessons of preparing and executing a well thought-out PEP isn’t standard procedure particularly in a make ready project. Inevitably, the lack of such planning causes projects to overrun schedules and blow project budgets. Why does this lesson have to be re-learned so often? Why can’t OTMR be implemented in many markets where broadband to the home is the goal?
I believe that the cause of these overruns may be attributed to the “bean counters” and to over-optimistic project plans devised to “sell” projects to stakeholders. A project-centric approach can and should make the difference and that will require a logical application of the One Touch Make Ready
[1] The first concept development and actual deployment of the One Touch Make Ready methodology was by Henkels & McCoy in the early 1980’s. Approximately 42,000 utility poles were surveyed and make ready construction was performed by one company in the Philadelphia region.