HomeMy WebLinkAboutCity of SLO Comment on NOI - Barriers to Wireline Deployments (WC Docket No. 25-253)City of San Luis Obispo, Office of the City Council, 990 Palm Street, San Luis Obispo, CA, 93401-3249, 805.781.7114,
slocity.org
December 16, 2025
Secretary, Federal Communications Commission
45 L Street NE
Washington, DC 20554
Re: Reply Comments – FCC Notice of Inquiry on Eliminating Barriers to Wireline Deployments (WC
Docket No. 25-253)
Dear Secretary:
The City of San Luis Obispo respectfully submits these comments in opposition to any federal
preemption of local authority over public rights-of-way (PROW). Local management of the PROW is
essential to protecting public safety, coordinating construction, preserving roadway investments,
and ensuring fair and equitable access to a limited public resource.
The Notice of Inquiry relies heavily on telecommunications-industry assertions that local processes
are a barrier to deployment. This does not reflect the reality in California. Our state already operates
under a comprehensive statewide franchise system (DIVCA) that grants providers streamlined access
to the PROW, includes a 60-day permit timeline, and requires cities to apply rules equally to all
carriers. Federal action in this area would conflict with an established and well-functioning state
framework.
In San Luis Obispo, PROW permitting is efficient, transparent, and predictable. Encroachment and
excavation permits are processed within an average of 15 working days, fees are cost-based and
nondiscriminatory, and our published standards and guidelines provide consistency for all applicants.
Preempting local authority would undermine our ability to manage traffic safety, pavement
preservation, stormwater systems, joint-trenching coordination, and the many competing demands
on a constrained PROW system. For these reasons, the City urges the FCC to retain local discretion
and avoid imposing federal fee caps, shot-clocks, or aesthetic limitations that would hinder effective
PROW management in California. Thank you for the opportunity to comment.
Sincerely,
Erica A Stewart
Mayor, City of San Luis Obispo
Confirmation Number: 20251216221011294https://www.fcc.gov/ecfs/filing/status/detail/confirmation/20251216221011294