OUR MISSION: To provide our customers with high-quality, efficient and reliable water, power and sewer services in a manner that values environmental and community interests and sustains the resources entrusted to our care.
MEMORANDUM
DATE: July 8, 2025
TO: Commissioner Kate H. Stacy, President
Commissioner Joshua Arce, Vice President
Commissioner Avni Jamdar
Commissioner Stephen E. Leveroni
Commissioner Meghan Thurlow
THROUGH: Dennis J. Herrera, General Manager
Barbara Hale, Assistant General Manager, Power
FROM: Richard Stephens, Power Utility Field Services Manager Grace Kay, Power Regulatory and Legislative Affairs Manager Matthew C. Ho, Power Distribution Engineering Manager
SUBJECT: Update on Street and Pedestrian Lighting Programs
Attached is the annual update on the street and pedestrian lighting programs and activities that the San Francisco Public Utilities Commission Power Enterprise has performed to date.
1 San Francisco Public Utilities
Commission
Street and Pedestrian Lighting Programs
June 2025
2 Table of Contents
1. I
llumination Systems ...................................................................................... 5 a. Street Pole Assessment and Rehabilitation ................................................. 5 b. Operations and Maintenance Performance (FY24-25) ............................... 5 c. Street and Pedestrian Lighting Improvements ............................................ 5 i. Private Developer Installed Streetlights ................................................. 5 ii. Series Loop Conversion .......................................................................... 7 iii. Coordination with other City Agencies .................................................. 8 iv. Board of Supervisors/311 Requests ...................................................... 11
2. Pole Use Policy ............................................................................................. 14 a. Established Use Policy.............................................................................. 14 b. Distributed Antenna Systems (DAS) ........................................................ 14 c. Public Safety Applications........................................................................ 15 i. Automated License Plate Recognition .................................................. 15 ii. Automated Speed Enforcement (ASE) ................................................. 16 d. DPW Regulations for Decorations Over Public Sidewalks and Streets ... 18
3. Regulatory Efforts ......................................................................................... 18 a. PG&E’s Streetlight rate increase .............................................................. 18 b. SFPUC coordinating advocacy with CALSLA (California Streetlight Association) ...................................................................................................... 20 c. Wholesale Service to San Francisco Streetlights and other Unmetered Loads ................................................................................................................. 20
Figure 1-1 800 Cesar Chavez– Private Development Project .................................. 7 Figure 1-2 Mission Rock Phase 1 .......................................................................... 11 Figure 1-3 BOS Woolsey ....................................................................................... 13 Figure 2-1 Upgraded DAS Installation on Folsom Street ...................................... 15 Figure 2-2 Installation of license plate recognition camera on Kezar Drive ......... 16 Figure 2-3 Speed camera at a crosswalk near Golden Gate Park; ......................... 17 Figure 2-4 Design concept under consideration for SOMA Pilipinas District ...... 18 Table 1-1 Streetlights Operations and Maintenance Performance ........................... 5 Table 1-2 City Owned Series Loop Conversion ...................................................... 8 Table 1-3 Streetlights Installed in Collaboration with Other City Agencies ......... 10 Table 1-4 BOS and 311 Requests .......................................................................... 13 3 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.
I
llumination 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.
I
n Fiscal Year 2024/2025 (FY24-25), Utility Field Services (UFS) repaired 1,295 streetlight outages and 30 knockdowns; and marked over 18,000 locations.
S
imilarly, during this period, Streetlight engineers coordinated with other city agencies and private developers, completing the installation of 156 light fixtures.
Streetlight engineers have implemented the new Helicore foundation technology to improve efficiency in installing new light poles at key locations. Although there were no extreme weather events that impacted lighting services, the Program continues to closely monitor illumination, telecommunication, pole use, and energy regulations.
T
he Pole Use Policy supports social and economic development, public safety, and quality of life in the City. The Distributed Antenna Systems Program works with mobile carriers to install small-cell wireless equipment on streetlight poles to expand 5G service and ensure continuous high-speed network coverage throughout the City. Public safety has been an important new use of streetlight poles in FY24/25, supporting crime detection and prevention programs deployed with the Police Department (SFPD) and the Municipal Transportation Agency (MTA).The Pole Use program has worked with Community Benefit Districts (CBDs) and DPW to review and install planter baskets, banners, and signs, and contribute to the Love Our Neighborhoods beautification program for hanging string lights and other decorative lighting to make communities more distinctive and welcoming.
4 Finally, regulatory and legislative compliance ensures awareness of regulatory and legislative policies affecting streetlighting services, including rates, and 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 as well as advocating for lower rates and/or a longer phase-in of rates through the California Public Utilities Commission’s General Rate Case proceeding.
5 1. Illumination Systems
a. Street Pole Assessment and Rehabilitation
Power Utility Field Services started the Streetlight Pole Assessment and Rehabilitation project in January 2015. 24,447 poles have been assessed. 782 poles were replaced as of June 2025, due to their severely deteriorated condition.
b. Operations and Maintenance Performance (FY24-25)
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 1-1 Streetlights Operations and Maintenance Performance
below 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 1-1 below.
Activities Quantity
1. Streetlight Outages Repaired 1,295
2. Streetlight Pole Knock Downs Replaced 30
3. DPW - X1104 Work Orders Completed 42
4. Request For Information/Notice Of Intent addressed 81
5. SF311 Cases received for streetlights 3,547
6. USAN requests for inspection services 18,477
Total 23,472
Table 1-1 Streetlights Operations and Maintenance Performance 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.
There are currently over 400 applications under review.
During the same reporting period, over 100 SL applications/requests were reviewed and responded to (311, redevelopment, internal city projects, and private development)
1 1 Each application/request may have multiple rounds of feedback and revisions.
6 7
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 1-2 below.
From the previous fiscal year, Utility Field Services continue to convert outdated series loops, and as of June 13, 2025 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 (overhead) transformers as part of the Sherwood loop conversion.
Figure 1-1 800 Cesar Chavez– Private Development Project
8 Junipero Serra is in construction installing the Helicore foundations and have ordered the new transformer-based poles (transformers located within the pole).
The nine converted loops will be removed from table in the next report.
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 1-2 City Owned Series Loop Conversion
iii. 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 1-3 lists the various streetlights that were and are being installed in collaboration with other City Agencies through Street Improvement, Streetscape, and Redevelopment Projects. 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.
Collaborations with Other City Agencies (Streetscapes/
Redevelopment)
Streetlight
Quantity Status
1. 2970J Joice Alley Improvement Project 3 Accepted
2. 1254 Fern Alley West Improvements 3 Accepted
3. Mission Rock Phase 1 62 Accepted
4. 1099I Transbay Park 12 In-Progress
5. 2148J Folsom Streetscape (2nd to Spear Street) 51 In-Progress
9 6. WW 762 Various Locations Sewer
Replacement No 20
5 In-Progress
7. I-280 SB Ocean Ave Project 5 In-Progress
8. 04-2Q4604 - de-energizing street light on the
23rd St. OC
2 In-Progress
9. Willie Woo Woo Wong Park 1 In-Progress
10. 2937J Various Locations Pavement Renovation 1 In-Progress
11. 3006J Alemany Interchange Improvements
(Phase 2) (Contract 3760)
3 In-Progress
12. Mission Branch Library 6 In-Progress
13. 2485J Upper Market Corridor Safety
Improvements (Contract 1000017336)
12 In-Progress
14. 2852J Muni Forward As-Needed Contract
CSO#8 (Powell-Sacramento)
2 In-Progress
15. 1207I Minna-Natoma Streetscape & Traffic
Signals
24 In-Progress
16. 2652J 19th Ave 28 In-Progress
17. 2378J Market-Octavia Living Alleys (1253I) 7 In-Progress
18. 3rd Street Light Rail (Mission Bay Loop) -
Illinois & 18th & 19th St (Contract 1236R)
9 In-Progress
19. 1550 Evans 13 In-Progress
20. 1832J Richland Bridge 8 In-Progress
21. 2961J 6th Street Pedestrian Safety Project
(Contract 1000015023)
37 In-Progress
22. Contract 36 Traffic Signal Upgrade 1 In-Progress
23. 160 Hahn St 2 In-Progress
24. 2949J Potrero Gateway Loop 3 In-Progress
25. 1082I Evans Streetscape 5 In-Progress
26. Powell Street Traffic Signal Upgrade-
Powell/Ellis Street, Powell/O'Farrell Street and
Powell/Geary Street
6 In-Progress
27. 2265I 13th Street Improvement Project 23 In-Progress
28. Main Streetscape 22 In-Progress
29. 1138I Ocean Beach Long Term Improvement
Project
4 In-Progress
30. 2357I Oakdale Lighting Improvements 12 In-Progress
31. 1297I Transbay Howard Streetscape Project 147 In-Progress
32. Contract 66 Traffic Signals 16 In-Progress
33. 2578J Embarcadero Enhancement Project The
Embarcadero between Bryant Street and Folsom
Street
2 In-Progress
34. 7th and Folsom Bike Signal Upgrade 2 In-Progress
35. 2314J Howard Streetscape 74 In-Progress
36. Sacramento and Sansome 23 In-Progress
10 37. 2453I Tenderloin Traffic Signal Upgrade 25 In-Progress
38. India Basin Park 401 Hunters Point 8 In-Progress
39. 2000 Marin 19 In-Progress
40. 2289I Geary Bus Rapid Transit Phase 2 24 In-Progress
41. 2408I VL 81 Post Webster 4 In-Progress
42. Mission Street Safety Improvements 3rd Street
& Mission Street to The Embarcadero &
Mission Street
69 In-Progress
43. 1947I Winston Drive and Lake Merced
Boulevard
2 In-Progress
44. 2955J Folsom Streetscape 165 In-Progress
45. 1261I Western Addition Pedestrian Lights JOC
J47-09 Contract 1003646
14 In-Progress
46. 2353I Innes Avenue Rebuild 59 In-Progress
47. 2752J Better Market Street Phase 1C 5 In-Progress
48. Potrero Hope Phase 2 43 In-Progress
49. Potrero Power Phase 1 32 In-Progress
50. Hunter's View Phase 3 24 In-Progress
51. Sunnydale 1A3 24 In-Progress
52. Visitacion Valley Zone 1 58 In-Progress
53. Hunter's View Phase 3 27 In-Progress
54. Balboa Reservoir Phase 1 43 In-Progress
55. Hunter's Point Shipyard 169 In-Progress
56. Treasure Island 1ADFGI 165 In-Progress
Total 1615
Table 1-3 Streetlights Installed in Collaboration with Other City Agencies
11 Figure 1-2 Mission Rock Phase 1
iv. Board of Supervisors/311 Requests
In response to public concerns about lighting in the City, SFPUC Streetlights has responded to both light shield requests and evaluation of streetlighting.
From July 1, 2024 to May 28,2025, SFPUC responded to 14 light shield requests and have completed 12 light shield requests.
PG&E has increased their costs for light shields to roughly $3,000; starting July 1, 2025 the SFPUC will no longer be accepting and submitting PG&E owned and maintained street light shield requests from the public due to these costs but will continue to respond to light shield requests on SFPUC owned and maintained lights.
SFPUC has performed lighting studies. As a result of the lighting studies, the below streetlight improvements have been made. Currently there are 282 open 311 photometric study requests that streetlight engineers are working through.
12 BOS/311 Request Streetlight
Quantity Status
1. Requests for lighting and cutting back
shrubbery Woolsey (BOS)
7 Accepted
2. Lighting Assessment for Bernal Heights
Library (BOS)
3 Accepted
3. BOS Peru between Avalon and Burrows 3 Accepted
4. BOS Dogpatch (Minnesota and Tennessee St
20th to 21st)
1 In-Progress
5. Capp St between 15th St & 16th St ; Mayor's
Office Call
6 In-Progress
6. Thor Avenue Street Lamp Request 2 In-Progress
7. Wholesale Produce Market 31 In-Progress
8. Diamond Heights Blvd & Upper Gold
Mine/Duncan/Upper Berkeley, and stairways
on Opalo, Onique, Colleen, and Coralino
9 In-Progress
9. Harrison and Precita Lighting Assessment
(BOS)
2 In-Progress
10. Upgrading lighting on Langton Street (BOS) 2 In-Progress
11. Request for lighting along San Bruno Ave
(BOS)
10 In-Progress
12. Lighting assessment: 400 block of Victoria
Street (BOS)
3 In-Progress
13. 19th Ave & Buckingham Way 6 In-Progress
14. Lighting Assessment for the 100 block of
Lobos Street (BOS)
1 In-Progress
15. Lighting assessment: on Ramsell St between
Holloway and Garfield (BOS)
3 In-Progress
16. Lighting Assessment on Geneva Ave (BOS) 10 In-Progress
17. Pacific Avenue - Additional Street Light
Request (BOS)
4 In-Progress
18. 495 32nd Ave- change PG&E light to LED
and HSS
3 In-Progress
19. Lighting Assessment for Cross St and Pope
St (BOS)
2 In-Progress
20. Larkin Street Stairs (BOS) 1 In-Progress
21. Lighting assessment - Executive Park Blvd &
Blanken Ave (BOS)
7 In-Progress
22. 21st between South Van Ness and Folsom
(BOS)
3 In-Progress
23. Heather Ave & Euclid Ave Lighting
Assessment (BOS)
2 In-Progress
13 24. Lighting Assessment: St. Germain, Mountain
Springs, Glenbrook (BOS)
19 In-Progress
25. Chenery Street and Diamond Street in Glen
Park (BOS)
3 In-Progress
26. Lighting assessment for Euclid and Masonic
(BOS)
3 In-Progress
27. Brannan St. Between 4th and 5th Street
(BOS)
4 In-Progress
28. Princeton Street/Tulane (BOS) 2 In-Progress
29. 44th Ave between Noriega and Ortega (BOS) 9 In-Progress
30. Ulloa and Claremont (BOS) 3 In-Progress
31. Fulton Street Safety Measures (BOS) 9 In-Progress
Total 173
Table 1-4 BOS and 311 Requests
Figure 1-3 BOS Woolsey
14 2. 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 SFPUC-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 2025, there are nearly 800 active DAS sites throughout the City, administered under Master License Agreements (MLA) with the mobile network providers/affiliates. Approximately half of these provide 4G or 5G service, and there are currently active applications from the carriers for upgrading an additional 30 sites to 5G and for deployment of 40 new 5G installations. Much of this activity is in service of the upcoming Super Bowl in 2026, to provide robust high-speed coverage for visitors to San Francisco. The local community will reap the benefit of this network enhancement for years to come. By modernizing the City’s telecommunications infrastructure with superior transmission speeds, lower latency, and increased capacity to users, the DAS program contributes to economic development and the well-being of residents. The SFPUC’s costs to administer and safely implement the DAS program are covered by fees charged to the carriers for licensing streetlight poles and conduit.
15 Figure 2-1 Upgraded DAS Installation on Folsom Street
c. Public Safety Applications
Public safety is a growing alternate use of SFPUC poles by other City agencies; the poles serve as structures for attaching sensors, and PUC streetlight circuits may be used to provide power.
i. Automated License Plate Recognition
The SFPD uses Stationary Automated License Plate Reader (ALPR) cameras for the authorized law enforcement purpose of rapidly identifying and locating vehicles of legitimate interest to law enforcement.
ALPR cameras are designed to read the rear license plates of vehicles that pass within the camera's field of view and to capture an image of the rear of the vehicle and its license plate (or lack of plate).
These images can be compared against databases of stolen vehicles and stolen plates, databases of vehicles associated with missing or kidnapped people, or compiled and queried for vehicles wanted as part of a criminal Figure 2-1 Upgraded DAS Installation on Folsom Street
16 investigation. In September 2024 SFPUC and SFPD executed a Memorandum of Understanding (MOU) to establish the terms and standard operating procedures for installation of ALPR cameras on PUC streetlight poles; in the initial rollout all cameras were solar powered, but there are plans for Streetlight circuit-powered installations once the Wholesale Distribution Tariff (WDT) 3 settlement with PG&E is finalized. As of June 2025, 174 ALPR cameras have been installed and are functioning to assist SFPD in detecting, preventing, and prosecuting crimes.
Figure 2-2 Installation of license plate recognition camera on Kezar Drive
ii. Automated Speed Enforcement (ASE)
In October 2023, the California State Legislature adopted Assembly Bill 645 authorizing six cities, including the City and County of San Francisco, to establish a Speed Safety System Pilot Program. This pilot is an opportunity for San Francisco to employ a powerful traffic safety tool that
17 offers a high rate of detection, and in conjunction with education and traffic engineering, can significantly reduce speeding, improve traffic safety, and prevent traffic-related fatalities and injuries. As part of Vision Zero SF, San Francisco’s Commitment to Ending Traffic Deaths, MTA installed detection cameras, radar, and other supporting equipment at selected locations around the City. In February 2025 SFPUC and SFMTA executed an MOU to define terms and operations for the Speed Safety System Pilot Program. Of the 56 camera equipment installations deployed in April and May of 2025, 40 are mounted on SFPUC poles and/or are powered by SFPUC Streetlight circuits. As of June 2025, SFMTA is using the activated cameras to issue warnings; however, starting in August 2025 – SFMTA plans to issue citations when the posted speed limit is exceeded
Figure 2-3 Speed camera at a crosswalk near Golden Gate Park; this location has issued the most warnings for excessive speed.
18 d. DPW Regulations for Decorations Over Public Sidewalks and Streets
City Code Sec. 723.1 Neighborhood Amenity (Love Our Neighborhoods) Projects went into effect in January 2024, “intended to facilitate residents’ and civic organizations’ promotion of neighborhood love, pride, and enjoyment.” SFPUC is collaborating with SFDPW, SFMTA, DBI, and SFFD 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.
Figure 2-4 Design concept under consideration for SOMA Pilipinas District While no formal Love Our Neighborhoods permits have been issued as of June 2025, the inter-agency working group has consulted with the Yerba Buena Central Business District and the American Indian Cultural District to provide design guidelines and assist these community groups in navigating City processes and procedures to achieve their creative vision.
3. Regulatory Efforts
a. PG&E’s Streetlight rate increase
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
19 on the agreement of a “phase-in” period. If an agreement was not reached, then costs would only increase in a single year. Since no agreement was made, the GRC impacts were 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 was a charge approved by the CPUC to encourage conversion of streetlight to LEDs. However, the IFC for decorative streetlights was 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). At the same time, the monthly IFC decreased by 99% (from ~$147,000 to $1,000/month), representing a significant savings to the City. The IFC was eliminated April 1, 2024. In total, the monthly facility charges that the City currently pays for PG&E-owned and maintained streetlights decreased by 21% over the last few years from ~$195,000/month to ~$154,000/month.
On September 30, 2024, PG&E filed its 2023 Phase 2 GRC filing with the CPUC, Application (A.) 24-09-014, which proposes increases to overall gas and electric distribution and generation base revenue requirement relative to current revenues. PG&E proposes monthly facility charge increases over the course of four years after a CPUC decision is issued.
Proposed increases for San Francisco’s LED rate schedule range from around 20% for LS-1E rates and nearly 80% for LS-1A LED lights (about 8% of San Francisco’s PG&E-owned streetlights are under the LS-1E rate, while around 85% are under the LS-1A). For high pressure sodium vapor lights (about 6% of the total), rates are proposed to increase between 33% and 90%. The remaining incandescent lights (<1% of the total) are proposed to nearly triple in cost by the end of the four-year incremental increases.
SFPUC is actively conducting discovery from PG&E through CALSLA.
In a recent data request response, PG&E stated that conversion of the remaining incandescent lights under CCSF Rate Schedules 4A and 5 is in progress and is expected to be completed in 2026; CCSF's Rate Schedule LS-1A equivalent High Pressure Sodium Vapor lights in San Francisco will get converted to LEDs on a case-by-case basis following PG&E's process of converting lights as they fail/burnout.
20 b. SFPUC coordinating advocacy with CALSLA (California Streetlight Association)
Through CALSLA, SFPUC is also coordinating advocacy with other members to lower the proposed increases and/or phase in the increases over a period longer than four years, which was successful in the prior GRC Phase I settlement. CALSLA’s testimony is due on August 25, 2025, and the newly authorized rates will likely take effect in late 2026.
c. Wholesale Service to San Francisco Streetlights and other Unmetered Loads
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. Under the Federal Power Act, the City has the right to access PG&E’s distribution grid to serve its customers and power municipal facilities, including streetlights. PG&E implements its obligation to provide distribution service according to the provisions of its Wholesale Distribution Tariff (WDT) on file with FERC.
Ever since the City transitioned to receiving service under the WDT in 2015, PG&E has continued to violate the terms of its open-access tariff and has implemented it in a way that has resulted in significant challenges for the City in providing Hetch Hetchy Power to its customers.
On September 15, 2020, PG&E filed proposed revisions to its Wholesale Distribution Tariff (WDT) on file with FERC. 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.
21 While the City litigated 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. Pursuant to the litigation above, the City and PG&E have reached a limited 10-year settlement agreement that will allow the City to continue to provide unmetered secondary service to new and existing streetlights and traffic signals. All other attachments on City- owned poles will require meters but will also be eligible for secondary service. The settlement was approved at the Board of Supervisors and thereafter filed at FERC.
The wireless telecommunications industry had similar concerns with the WDT3 changes to unmetered load service. Under the Distributed Antenna Systems Program (DAS), the City licenses some of its streetlight poles and SFMTA poles to wireless carriers to install antennas and related equipment (see section 2.b above). SFPUC has been providing power to those facilities, which the SFPUC can no longer do under WDT3. These changes resulted in additional costs and delays that hindered 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. This interim solution will be extended under the limited settlement agreement mentioned above. Under the settlement, PG&E is requiring SFPUC to apply for and sign a separate service agreement and install meters for each individual DAS installation.
However, this process PG&E has required to connect these devices has raised concerns for the SFPUC about the implementation of the settlement once it has finally been approved. In the past, the SFPUC has simply connected devices like this to its streetlighting circuits and then informed PG&E. Discussions about the specific business processes and practical implementations of the WDT3 settlement are ongoing.