1. LED Street Light Conversion
SFPUC LED Conversions
As of December 31, 2021, approximately 22,000 of the 30,000 decorative/cobra head/post top fixtures have been converted to LEDs.
The LED street light conversion from High Pressure Sodium (HPS) fixtures is complete. Field crews are currently assigned, as needed, to convert decorative LEDs and resolve cobra head LED discrepancies. The decorative fixtures will continue to be converted through 2022. Figure 1 shows the implemented conversions in green and the yet-to-be converted City-owned fixtures in yellow.
Figure 1 – City Street lights Eligible for LED Conversion Map Legend
Cobrahead - LED Conversion Complete
Decorative – Will be converted to LED
2. Street and Pedestrian Lighting Improvements
There were no street lighting improvement projects for the period July 1, 2021 through December 31, 2021.
Private Developer Installed Street Lights
When private developers install street lights in the Public Right of Way, SFPUC Street light Engineers will review and approve the plans. SFPUC will also ensure that the new street lights are operational prior to accepting ownership of the street lights on behalf of the City. Table 2 lists the descriptions of Private Developer projects, number of proposed street lights to be installed by the project, and current status of the project.
Table 2 – Private Development Installed Street Lights
(From 7/1/2021 to 12/31/2021)
Private Development Installed Street Lights Street Light(s) Quantity Status
1 1169 Market Street (Trinity Plaza Phase 4) 2 Completed 2 160 Folsom Street (Transbay Block 1) 17 In-Process
3 245 1st Street (Transbay Block 8) 12 Completed
4 75 Arkansas Street 4 In-Process
5 801 Brannan Street 12 In-Process
6 88 Arkansas Street 3 In-Process
7 950 Market Street 5 In-Process
8 1 de Haro Street 13 Completed
9 333 12 th Street 1 In-Process
10 Annie Alley Plaza 4 In-Process
11 3001 24 th Street 3 In-Process
12 1028 Market Street 1 In-Process
13 332 Bradford Street 1 In-Process
14 833 Bryant Street 5 In-Process
15 827-833 Kearny Street 1 Completed
16 815 Tennessee Street 4 Completed
17 1550 Evans Street 13 In-Process
18 300 Grant Avenue 2 In-Process
19 1990 Folsom Street 1 In-Process
Total 104
Series Loop Conversion
Low voltage conversion of the 5,000 volt (high voltage) series loops and associated change out of the existing Incandescent lights to LED is being performed by Power Enterprise’s Utility Field Services crews in specific
locations of San Francisco. 91.5% of the high voltage street lights have been converted as shown in Table 3 below.
Table 3 – City Owned Series Loop Conversions (as of 12/31/2021)
Locations Street Light
Quantity
Status
1 Portola Drive 19 Complete
2 Lakeshore – West of Sunset Blvd 46 Complete
3 Lakeshore – East of Sunset Blvd 105 Complete
4 Montgomery (Greenwich to Alta) 11 Complete
5 Junipero Serra (19th Ave to Ocean Ave) 37 In Construction 6 Sherwood (Casitas to Lansdale Ave) 22 Materials Ordered 7 Aquatic Park (Larkin to Polk) 3 Complete
8 Alemany Blvd (Putnam to Stonybrook St) 59 Complete
9 Alemany Blvd (Stonybrook to Mission St) 34 Complete
10 Forest Hill/Golden Gate Heights (Noriega,
Ortega, Pacheco, Funston)
56 Complete
11 Van Ness Ave Series Loop Conversion 300 Complete
Total 692
3. Street Light Pole Use Program
The SFPUC’s Pole Use Policy governs municipal and non-profit use of City- owned street light poles. The policy identifies a comprehensive review process of street light pole use requests from applicants, such as City agencies, community groups, business districts and other non-profit entities.
The SFPUC established the Street Light Pole Use Policy to streamline and regulate the use of City-owned street light poles in San Francisco. Street and sidewalk illumination are the most important use of street light poles—no other pole use may compromise street and sidewalk lighting operations and maintenance. The policy lists pole use priorities in the following order:
1. SFPUC use for street lighting;
2. Use by other city agencies for utility or other municipal purposes;
3. Decorative use by city agencies or community groups; and
4. Temporary event or holiday use by city agencies or community groups.
The review criteria include structural impact on the street light pole, physical impact on lighting performance and communication infrastructure, existing and proposed pole uses, electrical load, public support, and public benefit.
4. Holiday Lighting
In coordination with neighborhood groups and merchants to beautify San Francisco city streets during the holiday season, Utility Field Services crews install 240 snowflakes on Market Street, from Steuart to 8 th Street, 24 snowflakes on Leland Street, and 190 bell lights on 3rd Street.
Installation began on November 2, 2021 and removal was completed by January 15, 2022. Figure 2 shows examples of holiday lighting installations on Market and 3rd Streets and Leland Avenueast.
Figure 2 – Holiday Lighting Installations
Market Street Snowflakes
3rd Street Bells
Leland Avenue Snowflakes
5. Distributed Antenna Systems (“DAS” or “Antenna”)
The SFPUC owns approximately 30,000 street light poles, many of which are suitable sites for installing equipment to enhance wireless telecommunications services in San Francisco. The Antenna Program is a revenue-generating program to license existing SFPUC Poles for outdoor distributed antenna systems to be installed and operated by wireless telecommunications carriers using licensed spectrum and third-party hosts certified by the Federal Communications Commission.
There are currently four (4) carriers that have 12-year license agreements to attach to City-owned street light poles:
a. Verizon (works with the SFPUC directly or via Extenet, Modus or CBR), b. T-Mobile (works directly or through Extenet),
c. AT&T (through Modus or Extenet), and
d. Sprint (through Mobilitie or Extenet).
A Distributed Antenna System layer was added to the Power Enterprise’s Geographic Information System maps which indicate the street light poles that have been licensed by various carriers. As of December 31, 2021, there are 809 powered licensed sites on City-owned poles. As previously reported, potential revenues could total $30 million for these 12-year agreements.
However, the Federal Communications Commission issued an Order in September 2018 that limits the amount that municipalities may charge in permit and license fees for small wireless facilities on utility or other poles in the public right-of-way. In August 2020, the Ninth Circuit Court of Appeals upheld the Commission’s directive which results in the reduction in license fee revenue.
The new license fees will not be in effect until a new Citywide Master License
Agreement is fully executed. The SFPUC currently charges approximately $5,400 per pole per year in license fees for 2022. The new Master License Agreement would greatly reduce Antenna Program revenues as the new license fee would be set at $270 per pole per year.
6. Street Light Pole Assessment and Rehabilitation as of June 30, 2020 Power Utility Field Services started the Street Light Pole Assessment and Rehabilitation project in January 2015. 23,931 poles have been assessed, of which 634 poles were immediately replaced due to their severely deteriorated condition.
7. Operations & Maintenance Performance for FY 19/20
For SFPUC-owned street lights, Power’s Utility Field Services is responsible for routine operations and maintenance, as well as repair work such as pole knock downs. The table below shows the Utility Field Services’ performance on the requested inspections, field assessments, outages and pole knockdown repairs. Street light work associated with SFPW’s X1104 for the Sidewalk Improvement Restoration Program and others are also shown in Table 5 below.
Table 5 - Street Light Operations & Maintenance Performance (From 7/1/2021 to 12/31/2021)
Activity
Quantity
1. Street Light Outages Repaired 661
2. Street Light Pole Knock Downs Replaced 13
3. DPW - X1104 Work Orders Completed 6
4. Request For Information/Notice Of Intent addressed 174
5. SF311 Cases received for street lights 2,143
6. USAN requests for inspection services 20,425
Total
23,422
8. Coordination with Other City Agencies
Power Street Light staff is working to improve communications and efficiencies with various departments working in the streets, including Planning, SFPW and SFMTA, and private developers negotiating improvements with those same City agencies. Table 6 lists the various street lights that were installed in
collaboration with other City Agencies through Streetscape and Redevelopment Projects.
Table 6 –Street Lights Installed in Collaboration with Other City Agencies (From 7/1/2021 to 12/31/2021)
Collaboration with City Agencies
(Streetscapes & Redevelopments)
Street
Light(s)
Quantity
Status
1 22 Fillmore (16th Street Corridor) 59 Completed
2 Folsom Streetscape 61 Completed
3 Treasure Island Redevelopment 211 In-Process
4 Yerba Buena Island Redevelopment 73 In-Process
5 Harrison Streetscape 52 In-Process
6 Upper Haight Streetscape 109 In-Process
7 Folsom and Essex St (Transbay) 2 In-Process
8 Potrero Hope Phase 2 43 In-Process
9 Sunnydale 1A1 1A2 32 Completed
10 Sunnydale 1A3 24 In-Process
11 Mission Rock 62 In-Process
12 Pier 70 74 In-Process
Total 802
We encountered some challenges with recent development projects where the projects were permitted without the street light plans included. Street light staff is working with the developers to address deficiencies. The approval process may be improved by making sure that the street lights are included in the plans prior to the City issuing the permits for the projects.
9. Mission Bay Street Light Pole Issues
In April 2021, the SFPUC received public complaints regarding potentially hazardous conditions with several Mission Bay street light pole attachments.
SFPUC Utility Field Services crews investigated the issue and found that some luminaire arms with banner attachments unexpectedly became detached from the poles along Terry Francois Boulevard, China Basin Street, El Dorado Street and Long Bridge Street.
SFPUC staff met with Public Works staff, the City Attorney’s office, the pole manufacturer, and the banner applicant to discuss the cause of the arm failures. The pole manufacturer confirmed that these poles were not designed for attachments other than the luminaires. They were designed to support the luminaires and not for any other loads.
For public safety reasons, SFPUC requested SFPW to have the banners removed until a structural analysis is performed on the pole’s infrastructure when banners are attached.
Power’s Utility Field Services staff inspected every pole and made the poles safe. The SFPUC is working with Public Works on a policy to include a requirement that vendors perform structural, wind, and foundation analyses before permitting the installation of banners on the various pole types.
10. Regulatory Efforts
Large Rate Increases in PG&E’s General Rate Case for Streetlights Of the approximately 50,000 streetlights in San Francisco, approximately 40% of the streetlights are owned and maintained by PG&E. Although PG&E owns these streetlights, they are powered with electricity supplied by the SFPUC with Hetch Hetchy Power. PG&E bills the SFPUC for the operations and maintenance (non-energy) costs for these streetlights under the jurisdiction of the California Public Utilities Commission, which regulates PG&E’s operations.
As part of PG&E’s 2020 Phase 2 GRC filing with the CPUC, PG&E proposed changes to streetlight costs. PG&E, the California Street Light Association, and San Francisco negotiated a settlement of streetlight costs and filed a motion for adoption of that settlement in February 2021. CPUC Decision (D.) 21-11-016, issued on November 18, 2021, adopted the provisions of this settlement. The decision codified the settlement agreement to phase-in cost increases over of a 12 year-period, with costs moving by 1/12 of the way to the full cost each year.
The full cost for San Francisco is estimated at $2,600,000. This amount is $840,000 higher (48%) than the $1,7600,000 that the SFPUC would have otherwise paid if the rate formula from the previous 2017 GRC were to remain in effect. In other words, San Francisco’s streetlight rates for PG&E owned and maintained streetlights will increase by about 4% annually for the next 12 years.
On June 30, 2021, PG&E filed its 2023 Phase 1 GRC filing with the CPUC, Application (A.) 21-06-021, which as proposed would increase overall gas and electric distribution and generation base revenue requirement by 30% relative to 2022 revenues. This requested increase is one of the largest requests PG&E has made. The average PG&E customer’s electric bill, which includes electric energy procurement and other costs included in the GRC request, would increase by 18.1%, and the average streetlighting rates would increase by
9.0% based on existing revenue allocation methods.
PG&E identifies expense forecasts of $61 million for 5 streetlight programs contained in the GRC application for 2023-2026. PG&E expects to finish the San Francisco Regulated Output Streetlight replacements for $10.2 million by 2024. Additionally, PG&E plans to continue the Decorative Streetlights Replacement Program and plans to continue to re-inspect and refurbish unsafe Decorative Streetlights in San Francisco for a forecasted cost of $4.0 million.
San Francisco should also benefit from two PG&E system-wide programs: the ongoing LED Streetlight Conversion Program which has a forecasted cost of $32.5 million and the ongoing Non-Wood Streetlight Pole Replacement Program for a forecasted cost of $6.3 million. PG&E projects ongoing costs of around $2.0 million per year for its Streetlight Burnout Replacement Program.
PG&E Seeks to Terminate Wholesale Service to San Francisco’s Streetlights and Unmetered Load and Convert Hetch Hetchy Power Customers to PG&E Retail
While the CPUC regulates PG&E’s operations of PG&E-owned streetlights, the Federal Energy Regulatory Commission (Federal Commission) regulates the interconnection between PG&E’s distribution grid and Hetchy Hetchy Power customers. On September 15, 2020, PG&E filed proposed revisions to its Wholesale Distribution Tariff (Tariff) on file with the Federal Commission. Under PG&E’s Tariff, the City has the right to access PG&E’s distribution grid to serve its customers and power facilities, including streetlights. However, since the City’s transition to receiving service under the Tariff in 2015, PG&E has continued to violate the terms of its open-access Tariff and has enforced it in a way that has resulted in significant challenges for the City in providing Hetch Hetchy Power to its customers.
PG&E’s proposed revisions in its new Tariff filing (“Tariff 3”) are highly detrimental to wholesale customers taking service under this Tariff. Along with denying secondary service for new connections, PG&E would eliminate the current billing arrangement based on an agreed-upon formulae for streetlights and unmetered loads and require that these small loads be connected at primary voltage and metered. Under this requirement, the City would either have to install primary facilities to continue serving its streetlights or have them be served by PG&E at retail.
Since installing primary intervening facilities to serve streetlights would be both extremely cost and space-prohibitive, the City is at high risk of losing that load and would be unable to continue powering its streetlights as it has been authorized to do since the passage of the Raker Act. Should the City no longer be able to supply its streetlights with Hetch Hetchy Power, the City would have to pay higher rates under PG&E retail tariffs.
The City, with many other wholesale distribution customers, intervened in the Tariff 3 proceeding and protested the proposed requirements. Since December 2020, the City has engaged with PG&E in settlement negotiations at Federal Commission. PG&E, however, has moved forward with steps to convert the load to PG&E retail service. On September 30, 2021, PG&E filed revisions to its streetlight and traffic signal retail tariffs at the CPUC via Advice Letter.
PG&E also filed notice to terminate wholesale distribution service to streetlights and unmetered loads at Federal Commission on December 13, 2021 to go into effect by February 1, 2022.
The City has protested both filings at the California PUC and Federal Commission. In the meantime, the CPUC has suspended PG&E’s Advice Letter until August 29, 2022. On January 31, 2022, the Federal Commission issued an order suspending PG&E’s notice of termination until July 11, 2022, subject to refund, and set the matter for hearing and settlement. The City also presented an update on January 31, 2022 to the Board of Supervisors at a Land Use & Transportation Committee hearing regarding the status of City project disputes with PG&E, burdensome Tariff 3 requirements, and pending impact to the City’s streetlights and unmetered loads. At the Federal Commission, the City will continue to negotiate with PG&E in settlement procedures and move to litigate if a settlement cannot be reached.
The City has taken additional steps at the Federal Commission to prevent PG&E from terminating service to its streetlights and unmetered loads by making a filing outside of the Tariff 3 proceeding. Under the Federal Power Act, Federal Commission has the authority to issue an order directing PG&E to meet requests for service that comply with federal law requirements and is in the public interest. On August 20, 2021, the City filed an application for an order requiring PG&E to provide wholesale distribution service to future and current unmetered loads receiving service under the Tariff. That matter is still pending at the Federal Commission