To help achieve a greater understanding of pole attachment issues, NRECA has updated its June 2019 white paper examining the effect of electric cooperative pole attachment rates on rural broadband deployment. It finds that pole attachment rates are not a barrier to rural broadband deployment. In fact, pole attachment rental rates are de minimus in relation to the overall cost of deploying broadband. Other factors, primarily low population density and large capital expenditures, are more significant factors. NRECA sent a letter to FCC Chairman Pai highlighting the findings in this white paper when it was originally filed.