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SVP Standard - Small Cell DAS Attachments to SVP Streetlights OH 1570

City Council and Authorities Concurrent
March 25, 2025

Document
SVP Standard - Small Cell DAS Attachments to SVP Streetlights OH 1570
Meeting
March 25, 2025
Body
City Council and Authorities Concurrent
Original file
2.7 MB
Text extracted from the city's file for reading and search. Open the original on santaclara.legistar1.com. That file is the official record.

Small Cell / DAS Attachments to
SVP Streetlights

ISSUING DIVISION: Electric Engineering Signed by ____Kevin Keating___ SVP SPONSOR: Sachin Bajracharya, Principal Engineer Date Signed __15 August, 2023__ Revision: 03 Sheet 1 of 16
SECTION: Lighting OH 1570

Scope of Standard ........................................................................................................................... 2 Purpose of Revision ........................................................................................................................ 2 References ....................................................................................................................................... 2 Rescissions ...................................................................................................................................... 2 Definition of Terms......................................................................................................................... 3 Overview ......................................................................................................................................... 4 4G Streetlight Attachments ............................................................................................................. 5 5G Streetlight Attachments ............................................................................................................. 6 General Requirements ..................................................................................................................... 7 Loading Calculations .................................................................................................................... 10 Foundation Design ........................................................................................................................ 11 Radio Frequency (RF)Testing for FCC Compliance .................................................................... 11 Other Requirements ...................................................................................................................... 12 Streetlight Selection and Design ................................................................................................... 13 Signage .......................................................................................................................................... 14 Permits .......................................................................................................................................... 14 Public Outreach Requirements ..................................................................................................... 14 Pole Availability Request and Reservation Process ..................................................................... 16 Variances ....................................................................................................................................... 16

Table 1: Minimum Required Pole Replacement ........................................................................... 13

Figure 1: Sample 4G Communication Equipment Installation for reference. ................................ 5

Figure 2: Sample 5G Communication Equipment Installation for reference…………………….6 Figure 3: Example of Decorative Streetlights………………………………………....………….7 Figure 3: Example of Square Steel Pole……………………………..…………………………..13 Figure 4: Example of Round Tapered Aluminum Pole…………...……….…………………….13 Figure 5: Example of Sterner-type Pole…………………………………………………………13 By: J. Bruzzone
Small Cell / DAS Attachments to
SVP Streetlights

Silicon Valley Power
Drawn By: J. Bruzzone
Approved: 08/15/2023 SHEET 2 of 16
By: K. Keating
OH 1570
Rev.

3 Scope of Standard
This document is intended to provide third parties, who wish to attach communications equipment to Silicon Valley Power’s streetlights, guidelin es on SVP approved desi gn and construction practices associated with proposed attachments.

Purpose of Revision
Revision 3: This revision includes the following changes:
 Adds 5G Antenna Requirements
 Revises the noise testing section to allow for a factory test to satisfy the requirement.
 Minor edits to general requirements for mounting hardware.  Adds new pole reservation and variance request sections.  Revises the decorative streetlight requirements.

References
 American Association of State Highway and Transportation Officials, AASHTO LTS: Standard Specifications for Structural Supports for Highway Signs, Luminaires and Traffic Signals, 2001
 California Building Code 2013
 Electronic Code of Federal Regulations: Title 47 Chapter 1.  Merriam-Webster. Merriam-Webster, Web. 07 July 2016.
 SVP Standard Document UG 1000: Installation of Underground Substructures by Developers.
 SVP Standard Document SD 1275: RF Unit Clearances, most recent revision  SVP Standard Document OH 1560: Drill In Foundations, most recent Version  SVP Standard Document OH 1610: Pole Labeling, most recent revision  Lefebvre, Tony, 2014, Understanding Distributed Antenna Systems, TE Connectivity
 Rules for Overhead Electric Line Construction: General Order 95 Rescissions
The issuance of Revision 3 rescinds all previous revisions and versions of OH 1570. This is the current version of OH 1570 that may be referenced in contract documents, SVP design and construction documents, and other related documents.

By: J. Bruzzone
Small Cell / DAS Attachments to
SVP Streetlights

Silicon Valley Power
Drawn By: J. Bruzzone
Approved: 08/15/2023 SHEET 3 of 16
By: K. Keating
OH 1570
Rev.

3 Definition of Terms
Applicant: Wireless carriers, or other third parties, who wish to attach communications equipment to Silicon Valley Power’s streetlights and have submitted, or will be submitting, an application to the City for attachment approval.

City: City of Santa Clara or the City Council of the City of Santa Clara.

Distributed Antenna System (DAS): A network of antennas linked together through a fiber network that strengthens cellular coverage in discrete areas. This system can accommodate multiple carriers.

Streetlight: A complete lighting unit consisting of a lamp, mast arm, metal pole and associated hardware.

Master License Agreement: An agreement made between the City of Santa Clara and any outside entity that wishes to attach any type of equipment to City owned streetlights. The agreement sets terms and conditions for attachment and other procedures including cost.

Public Works Inspector: City of Santa Clara Public Works Department Inspector responsible for verifying the proper installation and repair of all facilities within the City rights-of-ways or City easements.

Silicon Valley Power (SVP): The Municipal Electric Utility of the City of Santa Clara.

Small Cell: An antenna that strengthens cellular service in an area by acting as a small cell tower.

Street Lighting: Portion of the SVP Electric System installed to provide lighting for City’s Public Streets

SVP Inspector: Silicon Valley Power Electric Inspector responsible for verifying the proper installation of electric facilities installed for the use of SVP. Also responsible for verifying that attachments to SVP facilities conform to SVP requirements.

By: J. Bruzzone
Small Cell / DAS Attachments to
SVP Streetlights

Silicon Valley Power
Drawn By: J. Bruzzone
Approved: 08/15/2023 SHEET 4 of 16
By: K. Keating
OH 1570
Rev.

3 Overview
The City of Santa Clara’s Electric Utility Department, Silicon Valley Power (SVP), owns and maintains existing and future streetlights within the public right-of-way in the limits of the City of Santa Clara. Wireless carriers may wish to install small wireless facilities and/or radio transmitters on these structures, in order to provide robust cellular/wireless coverage and capacity throughout the City. Other entities may wish to utilize these assets for their communication networks by attaching their own equipment. SVP is entrusted with ensuring its facilities are well maintained and do not significantly detract from City streetscapes or interfere with the operation of the Electric Utility. To follow this philosophy and maintain consistency, this document sets standard construction and design practices that must be followed when attaching wireless telecommunications equipment to SVP’s streetlights. The overall design philosophy is for equipment to be the least intrusive in appearance, size, and location.

If installations are available (e.g., have been installed in other jurisdictions) that are less intrusive than those described in this document, applicants are encouraged to present those installations to SVP for consideration and inclusion into this document.

Before attaching any communication equipment to City owned assets, the Applicant shall enter into a Master License Agreement with the City. All attachments shall be reviewed, inspected, and approved by SVP. Any attachments found to be made without a valid Master License Agreement, and SVP approval, will be removed at the equipment owner’s expense. Any work required to accommodate the equipment shall be at the expense of the equipment owner.

By: J. Bruzzone
Small Cell / DAS Attachments to
SVP Streetlights

Silicon Valley Power
Drawn By: J. Bruzzone
Approved: 08/15/2023 SHEET 5 of 16
By: K. Keating
OH 1570
Rev.

3 4G Streetlight Attachments

The following items shall be taken into consideration when applying to attach 4G equipment to streetlights.

 All equipment on the pole shall be covered except for SVP approved meters and disconnect switches.
o Antennas shall be attached to the top of the pole and covered by a single cylin drically shaped shroud
mounted to the top of the pole.
o Except for the meter and disconnect switch, equipment attached to the pole shall be covered by up to 2
rectangular encasements of matching shape and
dimensions. Encasements for the radio encasements
shall not exceed the following dimensions: 9” wide and
28” in height and 8” deep.

 The cylindrically shaped shroud covering the antennas shall not exceed the following dimensions: 11” in
diameter and 30” in height measured from the attachment point of the streetlight.
 Except for the antennas, pole mounted equipment shall be installed on the side of th e pole facing away from the street.
 All separate encasements and equipment mounted on the streetlight shall be arrange d in the same vertical
alignment.
 All pole mounted equipment shall be attached to the
streetlight a minimum of 8 feet above the pole foundation and sidewalk. Equipment that is not concealed under the cylindrical shroud may not ex tend above the top of the streetlight.

Figure 1: Sample 4G
Communication Equipment
Installation for reference.

By: J. Bruzzone
Small Cell / DAS Attachments to
SVP Streetlights

Silicon Valley Power
Drawn By: J. Bruzzone
Approved: 08/15/2023 SHEET 6 of 16
By: K. Keating
OH 1570
Rev.

3 5G Streetlight Attachments

The following items shall be taken into consideration when applying to attach 5G equipment to streetlights.

 Apart from the antennas, all equipment on the pole shall be covered, except for SVP approved meters and
disconnect switches.
o Antennas shall be attached to the pole at the same
height of attachment and contain the same dimensions.
o There is a limit of 3 antennas per pole.
o The antennas shall be mounted to the streetlight at least 20 feet above the ground.
o A disconnect switch is required for all installations. o A meter may be required at SVP’s discretion.

 The antennas shall be no larger than the following
dimensions: 5” wide, 21” high and 8” deep.
 Except for the antennas, pole mounted equipment shall be installed on the side of th e pole facing away from the street.
 Except for the antennas, all separate encasements and equipment mounted on the streetlight shall be arranged in the same vertical alignment.
 All pole mounted equipment shall be attached to the
streetlight a minimum of 8 feet above the pole foundation and sidewalk. Equipment shall not extend past the bottom of the mast arm.

Figure 2: Sample 5G
Communication Equipment
Installation for reference
By: J. Bruzzone
Small Cell / DAS Attachments to
SVP Streetlights

Silicon Valley Power
Drawn By: J. Bruzzone
Approved: 08/15/2023 SHEET 7 of 16
By: K. Keating
OH 1570
Rev.

3 Figure 3: Example of
Decorative Lights.

General Requirements

 All wires shall run inside the streetlight and through conduits in the footing. Best efforts shall be made to ensure that wires and conductors are not visible. Wires that are visible by necessity shall be neatly bundled and arranged, be visible for as short of a run as possible, and hang no more than 5” below the equipment.

 All wires shall be separated inside the pole from other existing cables and wires via a sleeve or inner duct inside the pole. All wire splicing shall occur at pull boxes or inside shrouds.

 No more than a 1/8-inch gap shall be between the surface of the pole and the mounted equipment. If needed shrouding can be used to close the gap.

 Communication Equipment a ttachments to decorative
streetlights will only be approved after the Applicant
demonstrates that they have assessed neighboring poles that are not decorative. If the applicant determines that an attachment to a decorative streetlight is required, a specialized design taking the intent of the pole’s aesthetics into
consideration shall be presented and discussed with SVP for approval prior to submitting an application.

 Historical Streetlights are not available for attachment.

 The shrouding and antennas must not impinge on the removal of the mast arm.

 Antennas and Equipment shall maintain Calif ornia’s General Order 95 clearances from overhead lines and service drops. Locations that cannot meet this requirement shall have their service converted to an underground service at the expense of the Applicant.

 Attachments may not interfere wi th the proper operation of th e streetlight. Blocking light, acting as an obstruction to maintenance activities, and causing voltage fluctuations in the existing lamp, are examples of such interference.

 Required signage and warning labels shall be installed in accordance with SVP documents SD 1275 and OH 1610.

 All communication cables shall have a minimum in sulation rating of 600V or be separately encased inside the streetlight.

By: J. Bruzzone
Small Cell / DAS Attachments to
SVP Streetlights

Silicon Valley Power
Drawn By: J. Bruzzone
Approved: 08/15/2023 SHEET 8 of 16
By: K. Keating
OH 1570
Rev.

3  Equipment conductors and fiber cables may not share the same conduit as the streetlight service. The Applicant’s fiber cable and electric conductors may share the same conduit if an innerduct is used to separate the fiber cable from the electrical c onductor in the co-shared conduit and said conduit sharing is allowed by applicable codes.

 Attachments to traffic signal poles are not addressed under this standard document, Applicants who want to attach to traffic signal poles sha ll coordinate their proposal with the Department of Public Works.

 Only one Small Cell installation per streetlight is allowed. The propagation of more than one signal through that antenna is not prohibited.

 Small Cell or DAS attachments shall not be physically co-located with any other wireless attachments that are not incorporated into the equipment shrouding.

 Communication equipment attachment methods and materials shall be clearly shown on submitted plans. SVP has a preference for clamps to be used as the mounting hardware.

 The communication equipment design shall prev ent animal nesting and access to the interior of the pole.
o Spikes may not be used as a form of animal control.

 In cases where a hole has been drilled into the streetlight to allow cable passage, a seal shall be created between the hosting equipment and the streetlight to prevent water, animal, and debris intrusion.

 All equipment shall be properly grounded per SVP Standard document UG 1000, with the use of a separate grounding wire directly connected to the ground lug at the base of the streetlight.

 Attachments shall not be added to mast arms.

 No attachments shall be added to streetlights that are part of an integrated foundation installed on a bridge or overpass.

 In areas where the attachment of the equipment has caused an increased corrosion risk, such as areas where galvanization has been removed or non-galvanized metal has been exposed to the elements, corrosion control methods shall be deployed.

 The fit, color, and finish of attachments shall match, or complement, the existing fit, color, and finish of the streetlight.

 When not designed specifically to be concealed behind a sign, all pieces of Small Cell equipment shall be in a vertical linear arrangement on one side of the pole.

 Equipment shall have long narrow profiles that avoid wide offsets from the pole.

By: J. Bruzzone
Small Cell / DAS Attachments to
SVP Streetlights

Silicon Valley Power
Drawn By: J. Bruzzone
Approved: 08/15/2023 SHEET 9 of 16
By: K. Keating
OH 1570
Rev.

3  Fans are discouraged and should not be utilized when possible. When fans are used, or the equipment produces a noise from another source, the Applicant is to submit a manufacturer factory test report showing that the decibel levels do not exceed the levels set in the Santa Clara Noise Ordinance, Chapter 9.10 of the Santa Clara City Code. After the installation is complete SVP may also require a site-specific acoustic study.

 In no case shall an attachment exceed the current equipment size shown below. o Antennas may not be more than 3 cubic feet in volume. o All associated equipment may not be more than 28 cubic feet in volume combined.

 The antennas and associated equipment may not extend the height of the pole more than 10% above its preexisting height.

 All current attachments to a pole, such as signs, decorative flowers, banners, pole number labels, etc. shall remain on the pole and remain attached in such a way that the attachment can fulfill its intended purpose.
o Pole number labels if incorrect or missing, must be corrected. o Where possible, equipment shall be mounted behind signs to minimize visual impact,

 Banners shall not be blocked from their current attachment points.

By: J. Bruzzone
Small Cell / DAS Attachments to
SVP Streetlights

Silicon Valley Power
Drawn By: J. Bruzzone
Approved: 08/15/2023 SHEET 10 of 16
By: K. Keating
OH 1570
Rev.

3 Loading Calculations
Any structural calculations and reports shall be performed and si gned by a California registered Professional Civil/Structural Engineer. The following criteria shall be taken into consideration and mentioned in the submitted loading report when a structural pole loading calculation is performed:

 The new pole and foundation shall be designed to AASHTO LTS 2001 Edition for a 110 mph 3 second gust wind speed.

 Existing poles and foundations, selected for attachment, shall pass evaluation with the latest AASHTO requirements.

 Poles shall be sized to include twin banners, each sized at 2’-6” X 7’.

 Depending on the area, other attachments required by the City may include flowerpots or Christmas lights. A visual survey of the area shall be performed to verify the decorative attachments that are to be included in the calculation.

 If a location fails its structural loading calculation, a new streetlight may be designed that can accommodate the load. All new pole designs shall follow the foundation design criteria and pole design criteria as defined in Table 1.

 All G.O. 95 clearance and strength requirements shall be met and maintained.

 Any holes drilled into the streetlight to accommodate equipment attachments shall be modeled in the strength loading calculations.

By: J. Bruzzone
Small Cell / DAS Attachments to
SVP Streetlights

Silicon Valley Power
Drawn By: J. Bruzzone
Approved: 08/15/2023 SHEET 11 of 16
By: K. Keating
OH 1570
Rev.

3 Foundation Design
Should a foundation require replacement, the following design considerations shall be utilized:

 Comply with SVP design standard UG-1541.

 The pole foundation shall be nominally 24” in diameter, and the anchor bolts shall form a bolt circle of 11-1/2” in diameter.

 The pole foundation shall include 2 conduits: one for wires relating to the Small Cell/ DAS and one for the streetlight’s power.

 Some existing streetlight poles utilize a drill-in foundation, as specified in SVP Document OH 1560. Drill-in foundations shall not be utilized for Small Cell or DAS node installations. If a desired location has a drill-in foundation, then the foundation will require replacement.

 The new foundation shall be located as close to the original location as possible.

Radio Frequency (RF)Testing for FCC Compliance
After a facility is approved and installed, field testing is required to be performed to ensure the facility meets the FCC’s standards. Residents within 50-feet of the facility shall be notified by the Applicant of the date that testing is scheduled to occur and can ask for testing of their dwelling units at no charge by contacting the Applicant. The Applicant will only be required to perform the testing of dwelling units only on the scheduled date, and wireless applicants will not be required to revisit a site for further testing of dwelling units after the initial testing has occurred. Testing may also be required when a site is modified (replacing/adding antennas or equipment), if the modifications may affect the antenna(s) output. The applicant will be required to file a report of their field test results with SVP.

Devices and associated equipment shall be UL listed and FCC certified or authorized for the intended use.

By: J. Bruzzone
Small Cell / DAS Attachments to
SVP Streetlights

Silicon Valley Power
Drawn By: J. Bruzzone
Approved: 08/15/2023 SHEET 12 of 16
By: K. Keating
OH 1570
Rev.

3 Other Requirements
 All Small Cell Sites or DAS nodes shall be equipped with a positive disconnect device, as described in SVP standard document SD 1275.
 Only SVP approved electric revenue meters shall be used.  Equipment service shall not be from the existing streetlight circuit. SVP shall be engaged to provide a new service point for the equipment’s use.
 All wires providing power to the Small Cell equipment shall be provided with a fuse.  The site shall not have generators or generator sockets.  City has the right to withhold certain locations for its own use.

By: J. Bruzzone
Small Cell / DAS Attachments to
SVP Streetlights

Silicon Valley Power
Drawn By: J. Bruzzone
Approved: 08/15/2023 SHEET 13 of 16
By: K. Keating
OH 1570
Rev.

3 Figure 5: Example of Round Tapered
Aluminum Pole
Figure 4: Example
of Square Steel Pole Figure 6: Example of Sterner-
type Pole
Streetlight Selection and Design
If the selected location for Small Cell, or DAS node placement, has the existing pole design as listed in Table 1, then the Minimum Required Replacement (MRR), shown on the right column of the table, is required. The MRR must be used when performing foundation calculations, even if the existing pole passes. If an existing pole fails the pole loading calculation, then the new pole design must look substantially like and have the characteristics of the MRR. If the existing light fixture is not an LED (light-emitting diode) than it shall be replaced by an SVP approved LED fixture during the installation of the communication equipment.

Table 1: Minimum Required Pole Replacement
Existing Pole Design Minimum Required Replacement
40’ square steel streetlight pole
(Figure 4)
Install a new round tapered aluminum pole
and mast arm with the LED light fixture
mounted 35’ from grade and new foundation.

30’ round tapered aluminum streetlight pole
and mast arm (Figure 5)
Utilize the existing pole and light fixture but
install it on a new foundation
30’ or shorter round tapered aluminum davit
streetlight pole
(Figure 5)
Install a new round tapered aluminum pole
and mast arm with the LED light fixture
mounted 30’ from grade and new foundation.
25’ or shorter round tapered aluminum
streetlight pole and mast arm
(Figure 5)
Install a new round tapered aluminum pole
and mast arm with the LED light fixture
mounted 30’ from grade and new foundation.

Sterner-type streetlight pole
(Figure 6)
Install a new round tapered aluminum pole
and mast arm with the LED light fixture
mounted 30’ from grade and new foundation.

For pole types not listed in Table 1, the streetlight design will be determined by SVP. If the existing design is still to be used, and the current streetlight fails the structural loading calculation, the replacement streetlight shall be indistinguishable from the or iginal design. The replacement streetlight shall not stand out when placed within a line containing other existing poles.

By: J. Bruzzone
Small Cell / DAS Attachments to
SVP Streetlights

Silicon Valley Power
Drawn By: J. Bruzzone
Approved: 08/15/2023 SHEET 14 of 16
By: K. Keating
OH 1570
Rev.

3 Signage
All Small Cell Sites / DAS nodes shall comply with the following signage requirements:

 Contact Information: The equipment owner’s name, a unique identification number of the Small Cell Site or DAS Node, and a 24 hour contact phone number.  The streetlight must have attached signage for RF, as required in SVP standard document SD 1275.
 All pieces of equipment that have the capability to be removed as one unit shall have the owner’s name and contact phone number placed on them as well as the streetlight.  SVP standard document OH 1610 provides more information about pole labeling requirements.

Permits
 All proposed work and traffic control devices within the City right-of-way or City easement require an Encroachment Permit. The City’s Department of Public Works shall be contacted to determine if a City Encroachment Permit is required.

Public Outreach Requirements
As a part of the Permitting process, the following public outreach requirements for small cell installations are to be followed:

 The Applicant is required to prepare mailing list and to notify all property owners and residents within 300 feet of the proposed facility via registered mail or certified mail.

 The Applicant shall provide the City’s Department of Public Works and Electric Department with the following:
o A copy of the letters and exhibits that were mailed to property owners and occupants within 300 feet of proposed facility.
o An aerial map showing the location of the proposed facility and an outline of the properties that are within 300 feet of the outreach area. o A list of all property owners, tenants, and occupants that were to receive the notification, including their address.
o An affidavit stating all property owners/occupants on the mailing list were sent letters and it shall indicate the date the letters were deposited with United States Postal Service.

By: J. Bruzzone
Small Cell / DAS Attachments to
SVP Streetlights

Silicon Valley Power
Drawn By: J. Bruzzone
Approved: 08/15/2023 SHEET 15 of 16
By: K. Keating
OH 1570
Rev.

3  The property owners shall be given 21 calendar days from the notification date to contact the Applicant with any questions or concerns.

 The notification letter shall contain the following:
o Clear description of the scope of work
o The target construction quarter and year
o Aerial map identifying the proposed location. As well as photos showing the proposed equipment and construction plans showing the site plan and elevations. o The Applicant Community Liaison’s name, phone, and email address whom property owners or occupants may contact with any questions or concerns. o The Applicant Community Liaison shall reply to all inquiries within 72 hours of contact

 The applicant shall log all contact with property owners or occupants. The log shall include the date, owner or resident’s name, address and the questions or concerns from the owner or occupants has regarding the facility.

 The Applicant shall provide a response (via email or letter) and attempt to resolve any issues prior to permit Issuance and shall keep a record of the complete text of each recipient’s comments, requests, questions, and Applicant’s responses and provide to City upon request.

 Upon completion of the notification period, the Applicant shall provide the Department of Public Works and Electric Utility Department with a compilation of all inquiries received (if any), including breakdown of the comments and concerns and, the inquirer’s name, address and contact information. The list shall be accompanied by an affidavit stating all inquiries received have been complied with and provided to the City, or that no inquiries were received for the proposed facility.

The Applicant shall work with the City to address any concerns to the maximum extent possible.

By: J. Bruzzone
Small Cell / DAS Attachments to
SVP Streetlights

Silicon Valley Power
Drawn By: J. Bruzzone
Approved: 08/15/2023 SHEET 16 of 16
By: K. Keating
OH 1570
Rev.

3 Pole Availability Request and Reservation Process
Applicants may request a particular streetlight is reserved for their use following the terms and conditions set forth in their executed Master License Agreement. Reservation requests shall be submitted to the SVP Engineer in charge of pole contacts in writing.

The reservation requests shall contain the following information:

 GPS coordinates of the streetlight
 SVP Streetlight identification number, if available
 Adjacent address
 Google KMZ file, or equivalent, that clearly shows the streetlight being reserved.

Once a reservation request is submitted the SVP Engineer will review the location to determine if the streetlight is already reserved by another applicant or for City use. If the streetlight is available, and the Applicant is in compliance with the other terms of their Master License Agreement, then the reservation may be granted.

An individual Applicant may request only one reservation within a 500-foot radius. Any poles previously reserved by the carrier that are within a 500-foot radius of a newly requested site must be relinquished.

Reservation requests will be processed on a first come, first serve basis. The applicant should allow for up to 2 weeks to process reservation request batches up to 10 poles. Requests numbering more than 10 poles may take up to 4 weeks to process.

Variances
Requests for a variance to this standard document shall be submitted to the SVP Distribution Engineering group in writing. The variance requests shall contain details and justification of the proposed variance that describes why the site cannot be brought into compliance with this standard document.

The applicant should allow for up to 4 weeks for a variance request determination.

Any requests for variances to this standard document must be granted prior to the submittal of an application for attachment. If an application is received that does not meet the requirements of this document without an approved variance it will be rejected as non-compliant.

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