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MEMORANDUM
DATE: June 17, 2024
TO: Commissioner Tim Paulson, President
Commissioner Anthony Rivera, Vice President
Commissioner Newsha K. Ajami
Commissioner Kate H. Stacy
THROUGH: Dennis J. Herrera, General Manager
Barbara Hale, Assistant General Manager, Power
FROM: Richard Stephens, Power Utility Field Services Manager RS Grace Kay, Power Regulatory and Legislative Affairs Manager GK Matthew C. Ho, Power Distribution Engineering Manager MH Ruth Huang, Streetlight Engineering Manager RH
Elisabeth Johns, Pole Use Program Manager EJ
RE: Update on Street and Pedestrian Lighting Programs
Attached is the semi-annual update on the street and pedestrian lighting programs and activities that the San Francisco Public Utilities Commission Power Enterprise has performed to date.
for DJH
2 San Francisco Public Utilities Commission
Street and Pedestrian Lighting Programs
June 2024
3 TABLE OF CONTENTS
1. EXECUTIVE SUMMARY ................................ ................................ ................................ ...... 4
2. ILLUMINATION SYSTEMS ................................ ................................ ................................ .. 6 a. Streetlight Pole Assessment and Rehabilitation ................................ .............................. 6 b. Operations & Maintenance Performance ................................ ................................ ........ 6 Table 2-1 Streetlight Operations & Maintenance Performance, FY23-24 ....................... 6 c. Street and Pedestrian Lighting Improvements ................................ ................................ 6 i. Private Developer Installed Streetlights ................................ ................................ ..... 6 Table 2-2 Private Development Projects, FY 23-24 ................................ ........................ 8 Figure 2-1 681 Florida. – Private Development Project ................................ ................... 9 Figure 2-2 1580 Pacific St. – Private Development Project ................................ ........... 10 ii. Series Loop Conversion ................................ ................................ .......................... 10 Table 2-3 City Owned Series Loop Conversions ................................ ........................... 11 d. Coordination with Other City Agencies ................................ ................................ .......... 11 Table 2 -4 Streetlights Installed in Collaboration with Other City Agencies, FY23-24 ................................ ................................ ................................ ....... 12 Figure 2-3 Treasure Island 1BCE ................................ ................................ ................ 13 Figure 2-4 Joice Alley –Interagency Project ................................ ................................ .. 14 Figure 2-5 2485J Upper Market Corridor –Interagency Project ................................ .... 15 Figure 2-6 Mission Rock Phase 1 ................................ ................................ ................ 16 e. Mission Bay Streetlight Pole Issues ................................ ................................ .............. 16 f. Board of Supervisors/311 Requests ................................ ................................ ............. 17 Table 2-4 Streetlight Improvements in Response to BOS/311 Requests ..................... 18
3. POLE USE POLICY ................................ ................................ ................................ ........... 19 a. Established Use Policy ................................ ................................ ................................ . 19 b. Distributed Antenna Systems (DAS) ................................ ................................ ............. 19 Figure 3-1 DAS Installation on Ingalls Street................................ ................................ . 20 c. Public Safety Applications ................................ ................................ ............................. 20 d. DPW Regulations for Decorations Over Public Sidewalks and Streets ......................... 21 e. Confirmation of Structural Calculation ................................ ................................ ........... 21
4. REGULATORY EFFORTS ................................ ................................ ................................ . 23 a. Costs Increases due to PG&E’s General Rate Case for Streetlights are Lower Than Previously Expected ................................ ................................ ....................... 23 b. PG&E Seeking to Terminate Wholesale Service to San Francisco’s Streetlights and Unmetered Load and Convert Hetch Hetchy Power Customers to PG&E Retail Customers ................................ ................................ ............... 24
4 1. EXECUTIVE SUMMARY
The San Francisco Public Utilities Commission (SFPUC) Street and Pedestrian Light Programs (The Program) are administered and operated by the Power Enterprise. The Program consists of three components – illumination systems, pole use policy including Distributed Antenna Systems (DAS), and energy regulatory & legislative compliance – to serve the City and County of San Francisco (City) and ensure public safety with attention to the interests of the community. The Program succeeds through the cooperative work of Power Enterprise’s Utility Field Services, Distribution Engineering, and Regulatory and Legislative Affairs departments.
Illumination systems include upgrading and improving aging streetlight systems, supporting new streetlight implementation in compliance with City standards and references, updating streetlight standards and guidelines, and coordinating with other City agencies regarding streetlight related matters.
Utility field staff and streetlight engineers are working diligently to provide reliable lighting services for all of San Francisco. Utility Field Services have assessed a total of 36,145 poles by way of SF311 reports as well as DPW’s X1104 for the Sidewalk Improvement Restoration Program (SIRP). Also, 633 aging SFPUC-owned series loop poles were replaced with only 59 poles remaining. Streetlight Engineers coordinate with other city agencies and developers, and have completed installation of 370 light fixtures. Streetlight engineers have implemented the new Helicore foundation technology to improve efficiency in installing new light poles at key locations). In Fiscal Year 2023/2024 (FY23-24) there were no extreme weather events that impacted lighting services, but the Program has continued to closely monitor illumination, telecommunication, pole use, and energy regulations.
The Pole Use Policy supports social and economic development, promotes benefits of products or services, and provides a means for collecting environmental data. The program has worked with Civic Center Community Benefit District (CBD) and Department of Public Works (DPW), , to review and install planter baskets, banners and signs, and also researchers and scientists to deploy sensors to monitor air quality in the City. SFPUC is assisting Public Works in development of Regulations for Decorations Over Public Sidewalks and Streets to allow specific conditions for the attachment of decorations by private parties over the public right-of-way. On February 22, 2023, SFPUC agreed to withdraw additional structural review by the permittees, and the banner permit program can resume pre-2021 operations.
Public safety is an emerging use of streetlight poles, with programs currently in the planning stages with the Police Department (SFPD) and the Municipal Transportation Agency (MTA). SFPUC and SFPD are currently working on a Memorandum of Understanding (MOU) to establish the terms and standard operating procedures for installation of public safety cameras on PUC streetlight
5 poles; a similar MOU between SFPD and SFMTA is already in place and cameras have been successfully installed on MTA poles.
The Distributed Antenna Systems (DAS) program – On March 14, 2023, the San Francisco Board of Supervisors approved the 2023 master license agreements (2023 MLA) with the mobile carriers for installation of their equipment on PUC poles. The DAS team is working with these carriers to plan the upgrade and expansion of their respective network coverage under the 2023 MLA terms. The DAS team continues to coordinate with Utility Field Services to address service interruptions for the carriers by resolving power issues to ensure continuous high-speed network coverage throughout the City.
Finally, regulatory and legislative compliance ensures awareness of regulatory and legislative policies affecting streetlighting services, including rates, advocating for San Francisco’s interests. Regulatory and legislative affairs have taken notice of large increases in PG&E’s rates for streetlights and is responding to PG&E’s termination of wholesale service to San Francisco’s streetlights and unmetered loads.
6 2. ILLUMINATION SYSTEMS
a. Streetlight Pole Assessment and Rehabilitation
Power Utility Field Services started the Streetlight Pole Assessment and Rehabilitation project in January 2015. 23,931 poles have been assessed. 760 poles were replaced as of June 2024, due to their severely deteriorated condition.
b. Operations & Maintenance Performance
For SFPUC-owned streetlights, Power Enterprise’s Utility Field Services is responsible for routine operations and maintenance, as well as repair work such as pole knock downs. Table 2-1below shows the Utility Field Services’ performance on the requested inspections, field assessments, outages and pole knockdown repairs. Streetlight work associated with DPW’s X1104 for the Sidewalk Improvement Restoration Program (SIRP) and non-SIRP are also shown in Table 2-1 below.
Activities Quantity
1. Streetlight Outages Repaired 787
2. Streetlight Pole Knock Downs Replaced 18
3. DPW - X1104 Work Orders Completed 17
4. Request For Information/Notice Of Intent addressed 43
5. SF311 Cases received for streetlights 1,827
6. USAN requests for inspection services 19,672
Total 22,364
Table 2-1 Streetlight Operations & Maintenance Performance, FY23-24 c. Street and Pedestrian Lighting Improvements
i. Private Developer Installed Streetlights
When private developers propose to install streetlights in the Public Right of Way, SFPUC Streetlight Engineers review and approve the plans. Streetlight Engineers also ensure that the new streetlights are operational prior to accepting ownership of the streetlights on behalf of the City. Table 2.2 lists the Private Developer projects, the number of proposed streetlights to be installed by the project, and current status of the project.
7 Private Development Projects Streetlight
Quantity Status
1 2 Henry Adams 2 In Process
2 333 12th Street 2 In Process
3 681 Florida 2 Complete
4 2000-70 Bryant 7 In Process
5 1028 Market 1 In Process
6 99 Ocean Ave 1 Complete
7 1001 Van Ness 3 In Process
8 2060 Folsom 1 In Process
9 Sutter Health CPMC (Mission Bernal Street
Improvement, previously St. Luke's) 3 In Process
10 Trinity 4 - 8th St. between Market & Mission
St 2 In Process
11 49 South Van Ness 1 In Process
12 300 Kansas 1 In Process
13 Mission Bay South (Block 6W) 1 In Process
14 4200 Geary 1 In Process
15 400 Paul 4 In Process
16 Mission Bay South (Block 6W) 1 In Process
17 Annie Alley 4 In Process
18 1 De Haro Street and 11 Division Street 13 In Process 19 1990 Folsom Street 1 In Process
20 200 Rhode Island - Proposed Streetlights 8 In Process 21 1580 Pacific Avenue, fronting Assessor Block
0573 Lot 011 Proposed SW Change 1 In Process
22 TZK Hotel on Broadway 6 In Process
23 519, 529 Powell - Street Lamp Base 1 Complete
24 88 Arkansas 3 In Process
25 PG&E Hunters Point Substation-1180 Evans 4 In Process 26 950 Gough 9 In Process
27 332 Bradford St 1 In Process
28 2752J Better Market Street Phase 1C 5 In Process
29 833 Bryant Street 5 In Process
30 827/833 Kearny 1 In Process
31 245 First St (Transbay Blk 8) 12 In Process
32 815 Tennessee (815 & 825) 4 In Process
33 400 China Basin (Mission Bay Block 9A) 1 In Process
34 75 Howard 7 In Process
35 300 Grant 2 In Process
36 160-210 Folsom St (Transbay Blk 1) 17 In Process
37 950 Tennessee 6 In Process
38 300 De Haro 3 In Process
39 2060 Folsom 1 In Process
40 633 Folsom 1 In Process
41 3001 24th 3 In Process
8 42 1990 Folsom 2 In Process
43 950-974 Market Street 6 In Process
44 801-855 Brannan 12 In Process
45 200 Rhode Island St 8 In Process
46 531 Bryant Street 2 In Process
47 Broadway Hotel 6 In Process
48 Shell Gas Station & Convenience Store 4 In Process
49 Wholesale Flower Mart 901 16th Street 3 In Process
50 3669 21st St, San Francisco, CA 94114 1 In Process
51 Transbay Block 2 East-Family-200 Folsom
Street 8 In Process
52 Transbay Block 2 West-Senior-200 Folsom
Street 7 In Process
53 2530 18th Street 3 In Process
54 850 Turk 2 In Process
55 1939 Market 2 In Process
56 250 4th St 1 In Process
57 750 Golden Gate 2 In Process
Total 221
Table 2-2 Private Development Projects, FY 23-24
9 Figure 2-1 681 Florida. – Private Development Project
10 Figure 2-2 1580 Pacific St. – Private Development Project
ii. 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 streetlights have been converted as shown in Table 2.3 below.
11 From the previous fiscal year, Utility Field Services continue to convert outdated series loops, and as of June 13, 2024 two loops remain to be converted. Due to community feedback, SFPUC is planning a capital project improvement to reuse the existing conduits and conductors and install pole-mounted transformers as part of the Sherwood loop conversion. Junipero Serra is in construction installing the Helicore foundations and have ordered the new transformer-based poles.
Series Loop Conversion Locations
Streetlight
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-Process
6 Sherwood (Casitas to Lansdale Ave) 22 In-Process
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
Table 2-3 City Owned Series Loop Conversions
d. Coordination with Other City Agencies
SFPUC Streetlight Engineers also collaborate with various City agencies to improve street lighting in the Public Right of Way including the Planning Department, Public Works and Municipal Transportation Agency. Table 2.4 lists the various streetlights that were and are being installed in collaboration with other City Agencies through Street Improvement, Streetscape, and Redevelopment Projects.
Collaborations with Other City Agencies
(Streetscapes/Redevelopments)
Streetlight
Quantity Status
1 Willie Woo Woo Wong Park 1 In Process
2 1254 Fern Alley West Improvements 3 In Process
3 2937J Various Locations Pavement Renovation 1 In Process 4 1261I Western Addition Pedestrian Lights JOC J47-09
Contract 1003646 14 In Process
5 2148J Folsom Streetscape (2nd to Spear Street) 51 In Process
12 6 2955J Folsom Streetscape 165 In Process
7 1099I Transbay Park 12 In Process
8 2970J Joice Alley Improvement Project 3 In Process
9 555 Larkin Street/500 Turk Street 1 Complete
10 3006J Alemany Interchange Improvements (Phase 2)
(Contract 3760) 3 In Process
11 Mission Branch Library 6 In Process
12 2485J Upper Market Corridor Safety Improvements
(Contract 1000017336) 12 In Process
13 2852J Muni Forward As-Needed Contract CSO#8 (Powell- Sacramento) 2 In Process
14 1207I Minna-Natoma Streetscape & Traffic Signals 24 In Process 15 2652J 19th Ave 28 In Process
16 2378J Market-Octavia Living Alleys (1253I) 7 In Process 17 3rd Street Light Rail (Mission Bay Loop) - Illinois & 18th & 19th St (Contract 1236R) 9 In Process
18 1550 Evans 13 In Process
19 1832J Richland Bridge 8 In Process
20 2961J 6th Street Pedestrian Safety Project (Contract 1000015023) 37 In Process
21 Pier 70 Phase 1 74 Complete
22 Sunnydale 1A1 and 1A2 39 Complete
23 Treasure Island 1BCE 175 Complete
24 Potrero Power Phase 1 32 In Process
25 Treasure Island 1 ADFGI 165 In Process
26 Yerba Buena Island Phase 1 74 Complete
27 Potrero Hope Phase 2 43 In Process
28 Hunter's View Phase 3 24 In Process
29 Mission Rock Phase 1 62 In Process
30 Sunnydale 1A3 24 In Process
31 Balboa Reservoir Phase 1 59 In Process
32 160 Hahn St 2 In Process
33 2357I Oakdale Lighting Improvements 12 In Process
34 Contract 66 Traffic Signals 16 In Process
35 Hunter's Point Shipyard 169 In Process
Total 1370
Table 2-4 Streetlights Installed in Collaboration with Other City Agencies, FY23-24
13 Figure 2-3 Treasure Island 1BCE
14 Figure 2-4 Joice Alley –Interagency Project
15 Figure 2-5 2485J Upper Market Corridor –Interagency Project
16 Figure 2-6 Mission Rock Phase 1
SFPUC Streetlight Engineers are working diligently and closely with interagency project counterparts to help ensure that photometrics studies and layout plans are reviewed early in the design phases so that construction is compliant with SFPUC streetlight requirements.
e. Mission Bay Streetlight Pole Issues
In April 2021, the SFPUC received public complaints regarding potentially hazardous conditions with several Mission Bay streetlight pole attachments.
Utility Field Services crews investigated the issue and found that some luminaire arms unexpectedly detached from the poles along Terry Francois Boulevard, China Basin Street, El Dorado Street and Long Bridge Street.
17 After making the situation safe, SFPUC staff met with DPW, the City Attorney’s Office, the pole manufacturer, and the banner applicants to discuss the cause of the arm failures. The pole manufacturer confirmed that these poles were not designed for any use other than the luminaires. The poles were designed to only account for the luminaire loads and not for any other uses.
For public safety reasons, SFPUC staff requested DPW remove the banners until a structural analysis could be performed on the pole’s infrastructure, showing when it is safe to attach banners.
Furthermore, Power Utility Field Services staff inspected every pole of that type and ensured that such incidents will not reoccur. SFPUC is working with DPW 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.
In July 2022, an investigative report was issued by a consultant concerning the luminaire arm fracture analysis.
Based on information provided in that report, the City (SFPUC and DPW) has installed data loggers on key Mission Bay poles to collect actual structural loading information. SFPUC and DPW will evaluate that data and determine next steps.
Data has been collected and a preliminary prestation was given by the structural consultant with potential recommendations. This information is under review.
f. Board of Supervisors/311 Requests
In response to public concerns about lighting in the City, SFPUC Streetlights has responded to 63 light shield requests and have completed 21 light shield requests. SFPUC has performed lighting studies. As a result of the lighting studies, the below streetlight improvements have been made.
BOS/311 Request Streetlight
Quantity Status
1 Anza Between Masonic and Wood Tree Trimming 7 In Process 2 Circular between Flood and Congo 6 In Process
3 1901 San Jose 8 In Process
4 Buena Vista Ave East and Duboce 4 In Process
5 19th Street between Caselli and Douglass 19 In Process 6 Thorp Lane between Douglass and Yukon 3 In Process
18 7 Cortland between Hilton and Peralta 5 In Process
8 BOS Ingerson and Jennings 3 In Process
9 BOS Dogpatch Minnesota and Tennessee St, 20th to 21st 1 In Process 10 Request for Lighting Assessment Harrison between 23rd & 24th
6 In Process
11 BOS 300 block of Congo between Monterey Blvd and Joost St
1 In Process
12 Lighting Assessment-Visitacion Valley Middle School (1971 Visitacion Ave)
17 In Process
13 Capp St between 15th St & 16th St; Mayor's Office Call 13 In Process 14 Thor Avenue Street Lamp Request 1 In Process
15 Wholesale Produce Market 31 In Process
16 Harrison and Precita Lighting Assessment (BOS) 2 In Process 17 Upgrading lighting on Langton Street (BOS) 2 In Process 18 Request for lighting along San Bruno Ave (BOS) 10 In Process 19 Lighting assessment: 400 block of Victoria Street (BOS) 3 In Process 20 Lighting Assessment: 100 block of Lobos Street (BOS) 1 In Process 21 Lighting assessment: Ramsell St between Holloway and Garfield (BOS)
3 In Process
22 Lighting Assessment on Geneva Ave (BOS) 10 In Process 23 Lighting Assessment for Bernal Heights Library (BOS) 3 Complete 24 Lighting Assessment for Cross St and Pope St (BOS) 2 In Process 25 Larkin Street Stairs (BOS) 1 In Process
26 Lighting assessment: Executive Park Blvd & Blanken Ave (BOS)
7 In Process
27 21st between South Van Ness and Folsom (BOS) 3 In Process 28 Lighting Assessment: Heather Ave & Euclid Ave (BOS) 2 In Process 29 Lighting Assessment: St. Germain, Mountain Springs,
Glenbrook (BOS)
19 In Process
30 Chenery Street and Diamond Street in Glen Park (BOS) 3 In Process 31 BOS Peru between Avalon and Burrows 3 In Process
Total 199
Table 2-4 Streetlight Improvements in Response to BOS/311 Requests
19 3. POLE USE POLICY
a. Established Use Policy
The SFPUC owns approximately 30,000 streetlight poles in the City, many of which are suitable for alternative uses. The Pole Use Policy governs municipal and non-profit use of City-owned streetlight poles. The policy identifies a comprehensive review process of streetlight pole use requests from applicants, such as City agencies, community groups, business districts and other non-profit entities.
The SFPUC adopted the Streetlight Pole Use Policy to streamline and regulate the use of City-owned streetlight poles in San Francisco. Street and sidewalk illumination are the most important use of streetlight 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
4. Temporary event use (e.g., amplified sound, festival lighting) by City agencies or community groups
The review criteria include structural impact on the streetlight poles, physical impact on lighting performance and communication infrastructure, existing and proposed pole uses, electrical load, public support, and public benefit.
b. Distributed Antenna Systems (DAS)
As of June 2024 there are over 800 active DAS sites throughout the City, all of which were installed under the original 2015 Master License Agreements (MLA) with the mobile network providers/affiliates. Approximately half of these have since been upgraded to 4G or 5G.
On July 12, 2023 the Board of Supervisors authorized the SFPUC General Manager and the SFMTA Director of Transportation to execute the 2023
20 DAS MLAs, which will have a 12-year term and could generate revenues in excess of $1 million. The PUC and MTA have since executed MLAs with five mobile network providers/affiliates, and are now working with these carriers to plan new DAS installations that continue to support the upgrade to 5G. This helps the City modernize its telecommunications infrastructure with superior transmission speeds, lower latency, and increased capacity to users, thereby contributing to economic development and the well-being of residents.
Figure 3-1 DAS Installation on Ingalls Street
c. Public Safety Applications
Public safety is a growing alternate use of SFPUC poles by other City agencies. In recent months the Streetlights team has engaged with SFPD and with MTA to support law enforcement and pedestrian safety initiatives by mounting sensor equipment on SFPUC poles; we anticipate more requests for such programs in the coming years.
21 d. DPW Regulations for Decorations Over Public Sidewalks and Streets
DPW is working on drafting regulations Article 5.10: Decorations over public sidewalks and streets to establish a new permitting process allowing for installation of decorative lighting and decorations above the public rights-of-way, both seasonally and long term.
The goal is to establish legislation of site-specific conditions to ensure a non-burdensome, appropriate ,and safe avenue for merchants, community groups, and neighborhoods to place decorations over the public right-of-way attaching to buildings, trees, poles, etc.
The regulations include guidelines such as an explicit permit application submittal and review process, and criteria to ensure an effective way for interested parties to decorate their neighborhood while maintaining public safety.
Approved Permits during FY22-23 include:
1. Leather & LGBTQ Culture District
2. Noe Valley Association
e. Confirmation of Structural Calculation
Under City Administrative Code, section 184.78, the Board of Supervisors granted DPW jurisdiction over banners on all utility poles within the City.
Per a streetlight pole incident in Mission Bay in 2021 (described in §2.e above), SFPUC requested DPW provide copies of their structural review in an effort to ensure the permitted banners do not cause structural issues with streetlight poles.
As of February 2023, DPW has agreed to collaborate with SFPUC on the requested improvements and SFPUC agreed to withdraw its request for additional structural review by the permittees. Contingent on continued collaboration and progress on these improvements, the banner permit program can return to pre-2021 operations. Banners will continue to be prohibited in Mission Bay pending the further investigation described above.
22 Figure 3-2 Valencia Lights – RentSFNow
23 4. REGULATORY EFFORTS
a. Costs Increases due to PG&E’s General Rate Case for Streetlights are Lower Than Previously Expected
As we reported in a prior Update on Street and Pedestrian Lighting Program, streetlight rates were increased as part of a negotiated settlement of the Pacific Gas & Electric Company (PG&E) 2020 Phase 2 General Rate Case (GRC) between PG&E, California Street Light Association (CALSLA) and San Francisco. California Public Utilities Commission (CPUC) Decision (D.) 21-11-016, issued on November 18, 2021, adopted the provisions of this settlement. The decision adopted the settlement agreement to phase-in cost increases over a 12 year-period, with costs moving by 1/12 of the way to the full cost each year.
Previously we reported that we expect these costs to be increased over the next 12 years to the full cost. However, the decision also conditioned this on the agreement of a “phase-in” period. If an agreement is not reached, then costs would only increase in a single year. Since no agreement was made, the GRC impacts are only limited to the ~4% increase in costs that occurred in March 1, 2022. At the same time, as part of the settlement agreement, PG&E discontinued charging the SFPUC an Incremental Facility Charge (IFC) for non-decorative streetlights, and halved the IFC for decorative streetlights (from $12.768/month to $6.226/month). The IFC is a charge approved by the CPUC to encourage conversion of streetlight to LEDs.
However, recently, the IFC for decorative streetlights has also been discontinued effective on April 1, 2024, since PG&E now considers LEDs to be a standard technology which does not warrant an incremental fee.
In summary, as of March 1, 2022, the monthly facility charges increased by 4% (from ~$147,000 to ~$153,000/month). These facility charges are not expected to increase in the foreseeable future without a new decision from the CPUC authorizing additional increases to facility charges. At the same time, the monthly IFC decreased by 99% (from ~$48,000 to $1,000/month), representing a significant savings to the City. Starting April 1, 2024, we expect the IFC to be eliminated. Put together, the total monthly facility charges that the City has to pay for PG&E-owned and maintained streetlights decreased by 21% over the last few years from ~$195,000/month to ~$154,000/month.
On June 30, 2021, PG&E filed its 2023 Phase 1 GRC filing with the CPUC, Application (A.) 21-06-021, which proposed increases to overall gas and electric distribution and generation base revenue requirement relative to 2022 revenues. The original requested increase of 36% is one of the largest
24 requests PG&E has made. The CPUC issued a decision (D.23-11-069) which authorized an increase of 22% over 4 years. The increases effects PG&E customer bills. As this relates to streetlights, however, the Phase 1 of the GRC did not alter the costs relevant to San Francisco.1 In summary, the costs from PG&E are not expected to change for now. These costs might however change in Phase 2 of the GRC which should be decided by late 2024.
b. PG&E Seeking to Terminate Wholesale Service to San Francisco’s Streetlights and Unmetered Load and Convert Hetch Hetchy Power Customers to PG&E Retail Customers
While the CPUC regulates PG&E’s operations of PG&E-owned streetlights, the Federal Energy Regulatory Commission (FERC) regulates the interconnection between PG&E’s distribution grid and Hetch Hetchy Power customers. On September 15, 2020, PG&E filed proposed revisions to its Wholesale Distribution Tariff (WDT) on file with the Federal Energy Regulatory Commission (FERC). Under PG&E’s WDT, the City has the right to access PG&E’s distribution grid to serve its customers and power municipal facilities, including streetlights. However, since the City’s transition to receiving service under the WDT 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 revisions to its WDT filing (WDT3), which went into effect on April 15, 2021, are highly detrimental to wholesale customers taking service under this tariff. Along with denying secondary service for new connections, PG&E eliminated the current billing arrangement based on an agreed-upon formula for streetlights and other unmetered loads and required that these small loads be connected at primary service 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 as retail customers.
Since installing primary intervening facilities to serve streetlights would be both extremely cost- and space-prohibitive, the City would be unable to continue powering its streetlights as it has been authorized to do since the passage of the Raker Act in 1913. The City would either have to pay higher rates under PG&E retail tariffs or spend in excess of $1 billion for large primary equipment that is unnecessary for safety or reliability and perform City-wide disruptive construction.
1 Streetlights are typically charged two different costs by PG&E, a facility charge (for maintaining the streetlight) and an energy rate (to supply the electricity). Since PG&E - owned streetlights are supplied by Hetch Hetchy Power, PG&E bills San Francisco only for facility charges. Typically, facility charges are changed in Phase 2 of the GRC.
25 While the City litigates this issue before FERC in the WDT3 proceeding, the City and PG&E negotiated an interim tariff and service agreement waiver (waiver agreement) that would in the meantime allow the City to continue to serve its existing unmetered loads. However, per the WDT3 requirements now in effect, all new unmetered loads will be required to apply for PG&E retail service. Upon conclusion of the WDT3 proceeding, the prevailing party will then be made “whole”, meaning that the losing party will pay the difference between the FERC wholesale and PG&E retail rates, and unmetered load delivery points would then be transferred to the appropriate jurisdictional service.
The wireless telecommunications industry had similar concerns with the WDT3 changes to unmetered load service. Under the Distributed Antenna Systems Program, the City licenses some of its streetlight poles and SFMTA poles to wireless carriers to install antennas and related equipment. The City has been providing power to those facilities, which the SFPUC can no longer do under WDT3. These changes would result in additional costs and delays that would hinder efforts to roll out 5G service in San Francisco.
After the industry filed its protest, the wireless carriers negotiated an interim solution with PG&E that would allow them to continue to install antennas and related equipment and receive service from SFPUC for an on-going monthly settlement fee paid to PG&E for every new connection.