​On October 29, NRECA, along with the Edison Electric Institute (EEI) and the Utilities Technology Council (UTC), filed comments in opposition to a petition by CTIA urging the FCC to expand pole access for wireless service providers. Specifically, CTIA asked the FCC to declare that lighting only poles are subject to all requirements of Section 224, and the Commission's poles attachment rules and to broadly prohibit all reasonable and nondiscriminatory construction standards that limit the encumbrance of the lowest portion of the pole, known as the "unusable space".