Regulatory reference · updated for FCC 25-38

The FCC pole-attachment shot clock, explained

Every deadline in 47 CFR §1.1411, broken down by order size, with the exact day-counts currently in force.

Reflects FCC 25-38 (Fifth Report & Order), effective May 7, 2026.

If you attach equipment to a utility pole regulated by the FCC, the utility doesn't get to sit on your application. 47 CFR §1.1411 puts a clock on every stage of the process — and PoleDocket's calculator and pipeline tracker both run on the exact numbers below.

The Regular Order timeline

A "Regular Order" is an application for the lesser of 300 poles or 0.5% of the utility's in-state poles. It's the default class most single-utility applications fall into, and it's the baseline every larger order class is measured against.

StageClockWhat has to happen
Completeness review10 business daysUtility deems the application complete and notifies you, or it's deemed complete automatically. A resubmission after rejection is deemed complete in 5 business days.
Survey / access decision45 daysUtility must grant or deny access within 45 days of a complete application.
Make-ready estimate14 daysDetailed, itemized estimate — pole-by-pole where requested — within 14 days of the survey response.
Acceptance / payment14 daysYou accept and pay within 14 days, or until the utility withdraws the estimate, whichever is later.
Make-ready — communications space30 daysUtility's own make-ready work in the communications space.
Make-ready — above communications space90 daysUtility's own make-ready work above the communications space (power space). The utility may take +15 days.
Self-help remedytriggers on missIf the 45-day survey or make-ready deadlines are missed, you may use a utility-approved contractor — communications space only.

Source: 47 CFR §1.1411; FCC 11-50; FCC 18-111 (2018 OTMR order); FCC 25-38, Fifth Report & Order.

Order-size classes change the clock

FCC 25-38 (effective May 7, 2026) introduced Mid-Sized, Large, and Very Large order classes on top of Regular — each with its own timeline and, for Mid-Sized and Large, an advance-notice requirement before you can even file.

Order sizeSurveyEstimateMake-ready (comms)Make-ready (above-comms)Advance notice
Regular45 days14 days30 days90 daysNone
Mid-Sized60 days14 days75 days135 days60 days
Large90 days29 days120 days180 days60 days + 30-day meet-and-confer
Very LargeGood-faith negotiation — no automated shot clockEncouraged, not required

Large Orders also carry a 30-day contractor-approval window, deemed approved if the utility doesn't respond. Completeness review (10 business days) and acceptance/payment (14 days) are unchanged across Regular, Mid-Sized, and Large.

Why this trips people up: a lot of secondary sources (including some pre-25-38 write-ups) still quote Mid-Sized as running on Regular-Order timelines with only a shorter advance notice. That's not what the adopted rule text says — Mid-Sized gets its own longer survey and make-ready windows, and its advance-notice requirement is actually the same 60 days as Large, not shorter. If a spreadsheet or another tool is quoting different numbers, check it against the rule text directly.

What "self-help" actually unlocks

If a utility blows the 45-day (or class-adjusted) survey deadline, or the make-ready deadline in the communications space, you gain the right to complete that make-ready work yourself using a contractor the utility has pre-approved. It doesn't apply above the communications space — power-space work stays with the utility no matter how late they run.

In practice, self-help eligibility is easy to miss if you're tracking deadlines by hand across several utilities — which is the exact failure mode PoleDocket's pipeline is built to catch automatically.

Frequently asked

Does this apply to cooperative or municipal utilities?
Only where FCC jurisdiction reaches — historically about 27 states for investor-owned utilities. As of NTIA's January 2026 General Terms and Conditions update, BEAD subgrantees that own poles (including co-ops and munis) must comply with FCC pole-attachment rules for the duration of the federal interest period, across their entire pole footprint — not just BEAD-funded poles. If you're unsure which regime a given utility falls under, PoleDocket tracks jurisdiction type per utility so you're not guessing.
What counts as a "business day" for the completeness review?
Per 47 CFR §1.4, business days exclude weekends and federal public holidays. A survey submitted the Wednesday before Thanksgiving lands very differently than one submitted a normal week — this is exactly the kind of off-by-one date math a calculator is worth using for.
Is this legal advice?
No. PoleDocket and this page track and explain published FCC deadlines; neither is a substitute for your own counsel, especially on a disputed or unusual application. See the disclaimer below.

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