​On September 3, NRECA, along with APPA, filed reply comments with the Federal Communications Commission (FCC) in support of a petition for declaratory ruling filed by the Edison Electric Institute (EEI).   The EEI petition urges the FCC to clarify that (1) the applicable statute of limitations for refunds awarded pursuant to section 1.1407 of the Commission's rules is the same as the two-year period prescribed by section 415(b) of the Act, and which apply to disputes to attachments on ILEC poles, and (2) refunds in pole attachment complaint proceedings are not “appropriate" for any period preceding good faith notice of a dispute. Doing so will eliminate inconsistent, arbitrary, and discriminatory treatment towards regulated electric utilities; encourage collaboration between pole owners and attachers; and promote the Commission's overarching policy goals to reduce disputes and advance broadband deployment.​