The party that wrote your make-ready estimate also set the rate, did the work and issued the invoice. PoleProof is the independent check on that bill: every line tested against your own attachment agreement and the rules that govern your pole, and every conclusion handed back with its source attached, for you to raise in your own name.
This page is that method in full. What gets checked, how a finding has to earn its way out, and what you can hold us to. Read it and you can audit the audit.
Four independent checks. Each catches a different category of error, and they compound, so a charge can pass one and still fail another. Three of them run today; the fourth carries its own label below, so you can see exactly which is which.
Line items against the rates, cost-share terms and scope in your signed attachment agreement.
Whether a charge is allocated to the correct party under FCC Part 1 Subpart J, your agreement, or the applicable state standard. This is a question about who owes a cost, not about whether the work was necessary.
Where a charge sits against what comparable work actually bills at, by pole owner and region. No benchmark figure is ever shown to you unless it draws on at least three distinct pole owners across at least three distinct clients. Below that floor we omit the comparison rather than show you a thin one.
The same pole and the same charge appearing twice across documents, and lines that reappear on a true-up having already been billed once.
Where the FCC's Subpart J rules reach the pole, the utility owes you a detailed, itemized estimate on a pole-by-pole basis if you ask for one, with documentation sufficient to determine the basis of every charge in it, and a detailed, itemized final invoice whenever the final cost differs from that estimate. Those are duties. What almost nobody does is test whether the itemization in front of them actually satisfies them.
And Subpart J does not reach every pole. It does not cover cooperative, municipal, railroad or government owned poles, and twenty three states plus the District of Columbia have certified that they regulate attachments themselves, which puts the federal rules aside for the poles they cover. On a pole outside Subpart J there is frequently no itemization duty at all.
Either way, itemization is a formatting duty. It tells you what the utility says it did. It does not tell you whether the charge belongs to you, and allocation is where the money is. That is the line this check is run on.
47 CFR 1.1411(e) and 1.1411(e)(3). The estimate and final invoice duties were codified at 1.1411(d) before the renumbering adopted in 2025; FCC 26-6, Comcast v. Appalachian Power, cites the current 1.1411(e)(3).
NCTA has told the FCC, citing data supplied by the electric utilities themselves, that actual costs exceed estimated costs 50 to 90 percent of the time. An advocacy filing in WC Docket No. 17-84, not an FCC finding, and worth reading as such. It still describes what every builder already knows.
Published modeling puts roughly 96 percent of touched poles at routine rearrangement cost. The 4 percent that get replaced carry about 45 percent of the total spend, and more than 60 percent at the high end. Your whole outcome turns on a few expensive decisions.
In February 2026 the FCC ruled for Comcast against Appalachian Power, applying a rule already on the books: you owe the incremental cost of making room, not a new pole. Months after the order the utility was still billing full replacement. The rule was never the problem.
A BEAD or RDOF award is a fixed number. Make-ready overruns do not come out of margin, they come out of homes served. In 2024 one national operator returned RDOF awards across three states citing costs primarily associated with extensive utility pole replacements.
You cannot staff your way out of this either. An outside plant engineer runs around $127,000 in base salary and mid-market builders are bidding against national carriers for them. Meanwhile the utility's own make-ready engineering is frequently outsourced to a firm billing per application. Both sides of the invoice are already automated. Only one side was being checked.
Only a deterministic check may create a finding. That means a lookup, a comparison, or arithmetic against something documented: your agreement, a tariff, a published formula, or a quantity stated on the invoice.
The language model layer extracts, classifies, explains and writes plain English. It is never the thing that decides an overcharge exists. That is the design rule everything else rests on, and it is what makes a finding reproducible by you rather than a matter of opinion.
The pass that tries to prove us wrong. Every candidate finding then goes through a second, separate pass whose only job is to defeat it. Is there a contract provision authorising this charge. Is there a reading of the formula under which it is correct. Is the extracted value ambiguous on the source document. Does a state rule differ from the federal one. Anything it defeats is downgraded or dropped. It runs as a distinct pass with its own logs rather than as extra instructions inside the first pass, because the point is to be able to show that it ran.
Deterministic, fully sourced, and adoptable by you. The only tier that enters a dispute packet, and the only tier we are ever paid on.
Shown to you and labeled as not findings. Never billable and never in a packet.
Logged internally for tuning and never shown.
The threshold starts high and comes down as the evidence base grows. An engine that under-reports builds a reputation for being right. An engine that over-reports hands the other side an argument on the first bad packet, and you do not get that back.
Every finding shows its work. A finding cannot be emitted unless it can populate all of: the source document, the page or line reference, the value extracted, the comparison value, where that comparison value came from, the arithmetic, and the identifier of the rule that fired. An item that cannot fill every field is not a finding. Every deliverable also carries the engine version, the rule library version and the benchmark snapshot date, so a finding can be reproduced later against the logic that actually produced it.
Federal Part 1 Subpart J does not reach every pole. Cooperative, municipal and state-regulated poles run on their own rules, and those are the poles a great many broadband builders actually attach to. So the rulebook that governs your pole is researched one state at a time, from the statute and the order that made it, and graded for confidence. That research program is described in full on how PoleProof researches and verifies.
Today, findings come from the federal baseline and your own agreement, which is where the strongest ground is anyway, and a state rule can inform an Observation. You see it either way, labeled for exactly what it is.
The control that will let a state rule originate a finding is designed and not yet running. It works like this: a licensed communications attorney clears the rule, that clearance is recorded and dated, and only then may the rule fire. Clearance is granted to the rule, once, offline. What you would receive is that cleared rule applied to your documents, with every input shown. A rule with no current clearance cannot originate a finding, because the lookup defaults to refusing rather than allowing. A state rule applied wrongly is worse for you than a state rule left out.
A finding is only worth having if it holds up when the pole owner pushes back. Two boundaries are what keep it standing, and both are deliberate.
The engineering determination is taken as given. We accept the pole owner's engineering call in full and audit the cost consequences of it. That is a discipline, not a gap: a cost conclusion grounded in your agreement and the governing rate rule is something the pole owner has to answer on the merits, while an argument about whether a pole truly needed replacing invites a competing opinion and stalls. So we do not evaluate whether a loading analysis was correct, whether a clearance determination was sound, or whether the work was over-scoped. Where an answer would turn on that judgment, we say so and recommend review by a licensed professional engineer. That boundary is fixed. It will not move as the engine improves.
A finding is a cost conclusion, not a legal one. PoleProof is not a law firm and its findings are not legal advice. You are the party of record in any dispute and you send it, which is precisely what keeps the finding yours and the record clean. Where a matter needs counsel we would rather hand you a name than stretch the service past what it can carry, and anything formally filed is filed by your own counsel.
The fee follows the outcome, not the effort. A finding withdrawn after a pole owner rebuts it is not billable, and it is logged.
That is the accountability mechanism we would choose even if nobody asked for it, because it puts the cost of being wrong on us and leaves none of it with you. We would rather be the auditor that does not get paid for being wrong.
More broadly, we are paid only on savings the pole owner actually concedes, evidenced by a document the pole owner itself issued. Never on a charge that merely looks wrong.
From the first finding onward we track three things: findings you adopt, findings sustained after a pole owner responds, and findings withdrawn.
The withdrawal rate is the one that matters, because it is the direct answer to anyone who suspects an auditor paid on savings is incentivised to over-claim. It goes on this page once it means something.
The floor we have set for ourselves is roughly 250 findings across at least five clients and three distinct pole owners. A rate computed on a dozen findings would mislead you in whichever direction it happened to land, and a number taken down the quarter it dips is worth less than no number at all. Once it is up, it stays up.
Every finding you receive names the clause, the rule or the benchmark it rests on, together with the document and the line it came from. You can go read that source yourself and decide whether you agree, which is the entire point of publishing the method rather than asserting the result.
What stays ours is the rule logic, the scoring and the contents of the benchmark dataset. Those are the work, and holding them is what lets us keep sharpening them for every client, audit after audit.
One free check. No account, no commitment. Send one invoice or estimate and the attachment agreement it runs under.
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