On June 27, 2022, IRAE submitted public comments to the FCC on its Second Further Notice of Proposed Rulemaking, Accelerating Wireline Broadband Deployment by Removing Barriers to Infrastructure Investment: Resolving Disputes Over Pole Replacement Costs. We appreciate the Commission opening up another round of commenting on this issue. The issue of pole attachment and pole replacement costs is both complex and of great importance, and taking a thoughtful approach to reforming policies surrounding both should result in better policy.