California Communications Infrastructure Update
As we look ahead to 2026, there are a number of active regulatory proceedings before the California Public Utilities Commission (CPUC) pertaining to communications network infrastructure. These rulemakings cover a wide array of issues, including network resiliency, pole access, infrastructure safety, and pole attachment documentation. Below is our high-level overview of the major developments that occurred in 2025 and a look at the expected rulings in the year ahead.
Network Resiliency Requirements; New Rulemaking
Pursuant to Decision 21-02-029, facilities-based wireline service providers must install equipment that will provide 72 hours of backup power for their facilities in Tier 2 and Tier 3 High Fire-Threat Districts, except those "facilities that do not need backup power, are unable to support backup power due to a safety risk, or are objectively impossible or infeasible to deploy backup power to." Facilities-based wireline providers must file Wireline Resiliency Plans each August. A Wireline Resiliency Plan is an advice letter in which providers may identify specific facilities that are exempt from the backup power mandate. The Wireline Resiliency Plans filed in August 2025 remain under review by CPUC staff. (Rulemaking 18-03-011).
In July 2025, the CPUC adopted an Order Instituting Rulemaking commencing a proceeding to update its network resiliency rules for both wireline and wireless service providers. The rulemaking could address a number of issues, including potential changes to the 72-hour backup power mandate, new rules regarding the use of mobile generators, potential enforcement mechanisms, and revised reporting requirements. A ruling from the assigned commissioner designating a complete set of issues and setting a procedural schedule is expected at any time. (Rulemaking 25-07-014).
Pole Database Proceeding
CPUC Decision 21-10-019 (Track 2 Decision) requires the five major pole owners (AT&T, PG&E, SCE, SDG&E, and Verizon) to create and manage pole databases that contain pole attachment data submitted by attachers as well as their own attachment data. The data is comprised of 20 data fields for each attachment provided in two phases. The Track 2 Decision required attachers to send the major pole owners eight of the 20 data fields beginning in August 2023 and ending in April 2024. The data for the remaining 12 data fields is more granular and pertains to the physical characteristics of the attached facilities.
On July 25, 2025, the five major pole owners and a group of attachers jointly filed a Petition for Modification (PFM) of the Track 2 Decision, along with a concurrently filed Extension Request. The PFM asks the CPUC to allow attachers to submit pole loading calculations they have prepared in lieu of the 12 data fields. On September 10, 2025, the CPUC's Executive Director granted the Extension Request and extended the deadline for attachers to submit the remaining 12 data fields to June 9, 2026. However, the CPUC has not yet acted on the PFM. (Investigation 17-06-027).
Pole Access Rulemaking
In October 2022, the CPUC issued Decision 22-10-025, which adopted new pole access rules in California that implement (1) One-Touch Make-Ready procedures, and (2) mandatory make-ready timelines. Both sets of rules closely align with those previously adopted by the Federal Communications Commission. The CPUC described the new rules as creating a "transparent and efficient pole attachment process that vests new attachers with greater options that place them in control of the work necessary to attach their equipment to utility poles."
After being dormant for more than two years, in May 2025, an administrative law judge (ALJ) issued a Ruling requesting comment on a Staff Proposal to amend the CPUC's Right-of-Way Rules (ROW Rules). The major recommendations in the Staff Proposal include new or revised rules pertaining to increased penalties for unauthorized attachments, contractor transparency, pole owner construction standards, pole replacement prioritization and self-help for attachers, pole reinforcements, extension of the ROW Rules to local governments, and overlashing. Parties filed comments in June 2025. (Rulemaking 17-06-028).
Rulemaking to Amend General Order (GO) 95
In October 2024, the CPUC initiated Rulemaking 24-10-005 to consider updates to GO 95, which governs the design and construction of overhead electric and communications facilities in the state. The proposed changes, which were introduced by the GO 95 Rules Committee, aim to incorporate Load Resistance and Factor Design (LRFD) into California's utility pole loading standards.
LRFD is a widely recognized engineering design principle and the current methodology used by the National Electrical Safety Code (NESC). By adopting LRFD, California would align its utility pole design standards with national practices, with the goal of improving infrastructure safety and reliability. The GO 95 Rules Committee proposed a phased "walk, crawl, run" approach, beginning with changes that maintain continuity with existing requirements while enabling future refinements to enhance safety outcomes and ensuring that the new methodology applies only prospectively.
The CPUC hosted a series of workshops in the second half of 2025 to discuss specific rule changes. These workshops culminated in a Joint Workshop Report, which was followed by a December 2025 ALJ Ruling posing a series of questions on the Report. Parties filed opening comments in response to the ALJ Ruling on January 16, 2026; reply comments are due on February 17, 2026.
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This advisory is intended to serve as a high-level overview of the most significant developments related to communications infrastructure in California in 2025 and what we may see in 2026. Please contact DWT for more detailed information.