9260 E. Stockton Blvd., Elk Grove, CA 95624
Frontier.com
1 April 29, 2025
VIA EMAIL
Eric Wier
City Manager
City of Crescent City
377 J Street
Crescent City, CA 95531
[email protected]
Subject: Crescent City Underground Utility District NO. 1 Dear Mr. Wier:
This letter is in response to the April 18, 2025, Notice of Public Hearing: Formation of Crescent City Underground Utility District NO. 1. for public comment concerning the city’s consideration of a plan to form an underground district in the area outlined in the map attached to the city’s notice. Citizens Telecommunications Company of California Inc. d/b/a Frontier Communications of California (“Frontier”) provides these comments.
In Frontier’s initial review of the proposed plan, we have determined Frontier’s facilities are already underground in a good portion of the area in and around the blocks between H Street and K Street and the public library.
In addition, Frontier points out that Pacific Power Rule 20A, as stated for the purpose of the formation of the district, does not apply to communications facilities such as those owned by Frontier. Frontier is regulated by the California Public Utilities Commission (“CPUC”), and, as part of our regulations, Frontier must file tariffs with the CPUC setting forth the rules and regulations that apply to Frontier.
In accordance with Frontier’s tariff for Citizens Telecommunications of California Inc., Local Exchange Tariff, at page 267, R1 General Regulations, Rule No. 29 – Facilities to Provide Replacement of Aerial with Underground Facilities, a request by a Government Agency, or the City of Crescent City in this instance, must meet the following conditions before Frontier will mutually agree to underground its facilities:
1. The governing body of the city or county in which such facilities are located has determined, after consultation and mutual concurrence with the Utility and after holding public hearings on 9260 E. Stockton Blvd., Elk Grove, CA 95624
Frontier.com
2 the subject, that under grounding is in the general public interest in a specified area for one or more of the following reasons:
a. Such undergrounding will avoid or eliminate an unusually heavy concentration of aerial facilities;
b. Said street, or road or right-of-way is in an area extensively used by the general public and carries a heavy volume of pedestrian or vehicular traffic; c. Said street, road or right-of-way adjoins or passes through a civic area or public recreation area or an area of unusual scenic interest to the general public; Frontier has included with these comments three pictures of its aerial facilities within the proposed underground district mapped area. Frontier points out that there is not a heavy concentration of aerial facilities. Nor do these streets evidence a significant concentration on each block of retail establishments or restaurants that would invite heavy pedestrian traffic.
Lastly, the map provided does not include a main public recreation area or scenic area of interest.
The civic areas that are included in the proposed underground district could possibly be the City Hall, the United States Post Office, and the public library. Frontier’s facilities by the library are already underground and around the other areas our facilities are minimal.
Frontier is happy to meet with the City of Crescent City and discuss further the proposed underground district at a convenient time for all. Please reach out to either Doug McAllister by phone at 951-970-4254 or [email protected] or myself at [email protected] or by phone at 916-686-3533 if there are any questions.
Sincerely,
Jenny Smith
Director, Government and Regulatory Affairs
Enclosures
Cc: Doug McAllister