But we also know there is go 95 and we work under that and that kind of sets our protocols for our routine patrols and inspections. In urban environments like San Francisco, we look at every pole every year. We do an inspection of that pole. We visually identify safety and reliability issues. If there are attachments on the poles, we will make sure there is poleloading calculations. Then we have our pg e pole inspection routine program. Thats an inspection we do for everybody. And then every five years we do a detailed inspection of poles and all the associated equipment. For facilities located underground, we do that inspection every three years. We also make minor repairs. In addition, the requirements of a patrol, our detailed inspections, are also used to identify potential go 95 violations that mr. Palmer discussed, and well make those repairs as necessary. The xurenunder cpuc go 165, tha means it needs to be looked at every year. We do the boring down every ten years. Weve been doing this more and more because we have seen these attachments put on poles. We have seen we call them unauthorized attachments because a lot of times you see this political signs, people climb up the poles and attach political signs to them and stuff like that. In urban areas, we stick to the one year so that we can make sure whatever people have been doing around the poles in urban environments, there are issues with that. If the pole is tested and it doesnt meet the requirements, well go through and make sure that it meets the requirements. We know there are a lot of issues with poles in urban areas, so we constantly are replacing poles here in San Francisco. Last year we replaced about 700 poles on a regular basis with our inspection. Supervisor fewer yes, supervisor walton. Supervisor walton just briefly before we continue, i want to make a motion to excuse chair mandelman without objection. Supervisor fewer yes. Supervisor walton perfect. Thank you. Supervisor fewer youre going to miss all this interesting stuff. Yeah, i know. I have a slide on undergrounding. So as has been mentioned before, any electric load added to poles must meet the strength requirements by go 95. What we do is require that any entity that would like to attach to a pg e pole, that that entity must enter into a license agreement with the joint Utility Department or be a member of the california joint pole association. Once that person is identified, then we determine if they will want to be pg es tenant, thats where we own the entire pole, or if they want to be a tenant and rent a space, or become a joint owner and purchase that space. So a Communications Company would purchase the space underneath our space if we own the whole pole and it becomes a jointly owned pole. In both cases the attacher must submit an application with a job package, purchase of intent, all the usual things, but in short, everyone must apply for permission to attach and to perform poleloading calculations to ensure safety. Thats why when we do see signs and other things that are attached to poles, we say please dont do it, because we have folks who will look at those poleloading calculations and ensure that the pole is safe and we realize and everyone realizes once this protocol is not followed, disaster could happen. Now, supervisor walton, you had brought up a point about is there a map . Well, we actually have a map. This is not under cpuc, but cpuc has opened up what is an oii, which is an investigation into having this kind of statewide map. We have what we call jump, the joint use map portal. We like to have acronyms that sound good. This is how we coordinate with our partners. Even the sfpuc can go into this portal, look at where all our poles are and make decisions about whats going on with the system and stuff like that supervisor fewer are they able to determine which ones are jointly owned and which ones are wholly owned by you . Yes. Supervisor fewer thats identified on juch jump . We just changed all the light bulb s to led. We mapped every pole that is sfpuc owned and what is pg e owned and we have shared that data so we know whose poles is what. Thats when we started discovering a lot of unauthorized attachments and we have made notations of those. We will start working through those issues. We do feel the pole loading is okay, but we will check them supervisor fewer okay. Supervisor walton just quickly, the average resident cant go in . No. This is protected, as mr. Palmer referred to, for Homeland Security reasons, it is protected. Only members of the joint pole authority and folks that we work with have access to this, and this is something that im sure is the cpuc is looking at during their investigatory period, as to providing a map what that portal would look like and those kinds of things. We are providing that information to them how we manage these poles so people can get this information. We do have what you need. We have details on the location, type of material, height, the circumference, remaining strength, the most recent inspection, test, and treat results, and all that information can be downloaded so that they can do the calculations. So as was mentioned, i did we did pop up a slide here so you can understand a little bit about the oii or order instituting investigation. I apologize to the public for the use of acronyms. This is where we are working with the cpuc and the other utilities to form this statewide database. So those workshops started in the fall of 2018. They continue now. We are talking about strategies on how to best ensure the integrity of affected communications and the electric supply infrastructure, and that includes poles, wires broadly speaking. We will make sure and what we are advocating for in that is the same information that is in our jump information. I was told i had five minutes, so ive been kind of going through this a little quick. Any time you have any questions, please ask. I do want to bring up undergrounding. We operate and maintain approximately 100,000 miles of overhead line. As i mentioned, we have 400 miles of overhead distribution. We are right now evaluating what is best for undergrounding versus having aboveground poles. It does depend on what the soil is. It depends on really the geographic location, just to say in general, because yes, a lot of people say why dont you just underground your lines . Is it really all about cost . It isnt all about cost. It is about what is underground. We know undergrounding are not immune to weather. I will tell you when you underground lines in minnesota, they have problems with gophers. They actually had a gopher guy that does gopher surveys to make sure their underground lines stay safe. I dont think we have gophers here in San Francisco, but we have and thats what i mean by when you talk about the geographic difference, what is it that affects with what goes above ground and below ground. So we also know that underground lines, when they do get affected like in an earthquake, they do take longer to repair. When you look at a situation like all of the underground transmission lines we have in San Francisco, if there was to be an earthquake, the earth shifts, breaks those lines, it will take a long time to bring those lines back up. We have made we have taken measures to mitigate for that just so you guys know. I dont want you to think that pg e is worried about the underground lines. We have a warehouse next to our martin station that has all your transmission lines, the bay area restoration warehouse, it has all the transmission lines and poles so that we can very quickly set up new transmission lines while we repair the underground lines so San Francisco will still have power if you have a large earthquake. Supervisor fewer okay. Thats great. Any questions or comments . Yeah, supervisor, welcome to the discussion. Is it true that undergrounding saves in terms of energy loss, so rather than being above ground, underground when youre distributing the energy theres not as much loss when its underground . That depends and thats one of the issues we would look at when it comes to undergrounding here in San Francisco. When you have transmission lines underground and you have distribution lines undergrounding, if theyre far apart enough, they can flow electricity, it might be more efficient or not. But as you put the lines closer together and we have very busy utilities under your streets in San Francisco, you have a problem called impede entans that will reduce the effectively of the power going through the wire. We cant go in and say well put 12 transmission lines down a street, because if you have 12 transmission lines you would have to put in a special cooling system so the impedance will be used. In general its more efficient unless its in proximity . Thats really what it depends on, what the proximity is and do you have enough room. We faced a lot of challenges with some projects in supervisor waltons district where in some of the Industrial Areas we have a lot of transmission lines underground. When we look to put distribution underground we actually cant fit it so we have to move some things around. Minus transmission lines, the distribution line is more efficient; correct . I it depends on the application. I mean, i the lines are efficient, you know, when we go in and put those lines in, the efficiency of that line depends on where its geographically located. Do you guys voluntarily underground or are you doing it when were requesting it . Is it. I couldnt rightly say because we do have more lines underground here in San Francisco than not, but we work with our regulator, the cpuc, to decide if lines go underground or not. You dont know the answer . No, i can get back to you. If you voluntarily do it, its usually when we request it on the city side. Youre not voluntarily undergrounding . We voluntarily underground our transmission lines. Do you want to take that one . Im the rule 28 program manager. The rule 28 is set up so that requests from cities and counties can come into pg e and other utilities to convert overhead lines to underground and the tariff permits the allocation of work credits. Cities and counties accrue these work credits very much like Airline Miles and redeem these credits for future undergrounding credits when they have a sufficient number of work credits. For new construction, those are under other rules, such as rule 2, rule 15, and rule 16. So many times those new Construction Projects will be done from underground from the getgo. Specifically with the conversion of overhead to underground is rule 20. So do you voluntarily do it or you do it based on what were requesting . That last part sounded like rule 20 was when we require a new construction, because i know often new construction in San Francisco will require it and so then you have to abide by that, but otherwise youre not voluntarily doing it, you prefer it above ground . Thats correct. So what the rule 20 a because we are a regulated investorowned utilities, we must follow all the various tariffs and rules that are provided by the cpuc. Rule 20 has three parts. Rule 20 a , rule 20 b , and rule 20 c . Rule 20 a which is where rate payer dollars utilized to convert overhead to underground facilities and as mentioned the cities and counties accrue work credits and convert these work credits for future projects, and a future project is designated by passing a resolution. A rule 20 b project would be when a city or a county also passes a resolution, but it would be a selftaxing measure for those residents within the designated underground district. And a rule 20 c is more or less a just a cash transaction. When someone wants to underground a specific facility. These are the ways that cities and counties have at their disposal to underground overhead to underground lines. I will mention also that the cpuc has created an order instituting rulemaking to readdress a lot of the concerns that they have heard from cities and county. The city and county of San Francisco is a party to this process. The oir started in 2017. One of the things that the cpuc is looking at is one of the aspects is the rule 20 work credit allocation methodology. Currently the city of San Francisco had a significantly large project. And so they have been allowed through exemption by the cpuc to do approximately 48 million worth of undergrounding sorry, 48 miles worth of undergrounding, but that unfortunately, the city of San Francisco has now mortgaged approximately 14 years of future years. So this needs to reach a zero balance of work credits, you need to wait 14 years to start undergrounding overhead lines supervisor fewer that translates to say that the rate payers will be paying this off for another 14 years; is that correct . Because this is really by rate payers . There is the the Capital Projects themselves are paid for when theyre entered into pg es rate base, so at the completion of the project. So those projects are essentially recovered through pg es ratemaking process. The work credits, they are not collected in advance from rate payers. So as pg e distributes those work credits in the cities and counties, there is not a commensurate treasury or a bank of rate payer dollars that is utilized supervisor fewer so the rate payers will continue to pay this until were at a zero balance in 14 years . Is that what you not quite. Its the capital costs of the project is in our rate base and is amortized over the period of that Capital Project supervisor fewer so weve already done weve used our 20 a sort of in San Francisco when we did some undergrounding and my what im hearing back is we ran out of money to do the rest, but well be paying it for another last year it was 15 years. So i think what youre telling me is 14 years. Yes. Actually, its going to be 15 years before you reach a zero balance of work credits. I just want to emphasize these are work credits, these are not rate dollars. The city and county of San Francisco in their comments, opening comments, in the oir proceeding with the cpuc has made mention of this to examine the work credit methodology, given that the city and county of San Francisco has significant ambition to underground more overhead lines to underground. Supervisor fewer okay. Any other questions or comments . Okay. Thank you very much. Thank you. All right. So weve heard from pg e, who brings in energy and electricity. Now were going to hear from communication lines. I think we have kammy blackstone from at t. Im assuming, ms. Blackstone, that at t is part of this association of northern californias joint policy i didnt even know that existed joint pole association; correct . Indeed we are. Supervisor fewer and im assuming, ms. Blackstone, that you are joint owners of these some of these 22,000 jointly owned utility poles; is that correct . Indeed we are. Supervisor fewer okay. Good morning, supervisors. Thank you very much for having this hearing. My name is kammy blackstone and i am the director of external affairs for at t and looking forward to this presentation. Im here not only as a director of at t but a city longtime resident of San Francisco. Im a part of this community that has concerns about overhead wiring. I wanted to start by presenting some basic facts about poles in california. Youve heard quite a bit already from the cpuc and pg e. Just to go over it again, youre looking there in this slide just some basic facts about the poles in california. We are in the Communications Zone, and you had mentioned seeing a lot more additional equipment. You are seeing that additional equipment in that Communications Zone as more people entered the market. So im going to refer to, like sonic or monkey brains or some of the other utility providers you will see up there supervisor fewer they are all members of this other organization that i didnt know existed . You know, i would say you need to ask them. I know we are required to allow them space in that area. Supervisor fewer okay. So our inspection and Maintenance Plan is kind of covered here. We also follow all the regulations that are used throughout the state of california. So we stay with we comply with all the state and federal regulations, and its our interest of course to keep our customers and workers safe and to keep our services reliable. This slide shows you all of the different rules that we work under. Theres this is just a partial list of the most important and most relevant to this discussion which youve heard a lot today is go 95, and thats 600 pages of state rules for overhead line design, construction, and maintenance. Of course as you heard earlier, this was developed over years of workshops and reviews and collaboration between all of the utilities. So on this slide, im just kind of going over the attachments and what we do. At t is attached to approximately 26,000 poles in San Francisco. Now, of those, 2,000 are solely owned by at t. The majority we are coowners with pg e and you heard a little bit about that earlier. Our inspections as far as maintenance and inspections and protocols, our techs are required to inspect the infrastructure for safety issues every single time they touch our equipment. So if you are running around San Francisco, you see our trucks everywhere. So we are constantly doing these evaluations. They actually call it a tzone inspection that they need to do, where they look up the pole and then they look both directions as far as the ooi can see just to notice if there are any irregularities or anything that needs to be repaired and they are empowered to repair that on site or file a report immediately. Go 95 also lays out a timeline that you heard earlier for routine inspections at longer intervals, but we feel here with at t and in San Francisco which is so dense and pop you you populace, we are identifying the pole for integrity. Additionally every provider attached to a pole is obligated to notify the other users of that pole if they identify a safety issue. Which means if pg e is looking at a pole and they see some problem with our equipment, then they notify us right away and we would do the same if we saw another provider having a