meeting safetyfactor requirements. To ensure accurate load calculations, SED’s proposed Rule 94.3D would require the “actual specifications” of all pole attachments to be used in load calculations. SED disagrees with the position of several parties, summarized below, that it is reasonable to use conservative values in load calculations instead of “actual specifications.” SED responds that load calculations based on conservative values can result in poles that are unbalanced or overloaded. SED warns that if its proposed Rule 94.3D is rejected, utilities will continue to use unsafe conservative values in load calculations. SED acknowledges that the problem addressed by its proposed Rule 94.3D is not unique to CMRS facilities. However, because this proceeding focuses on CMRS carriers, SED’s proposed rule must likewise focus on CMRS facilities. SED recommends that its proposed rule be applied to all pole attachments in future Commission proceedings. CFC, IBEW 1245, and TURN take a neutral position on SED’s proposed rule. TURN comments that it agrees the proposed rule will strengthen protections against pole overloading and will not have significant costs for ratepayers, TURN is concerned that the proposed Rule 94.3D does not specify who would perform and retain load calculations. SED’s proposed rule is opposed by AT&T Mobility, CCTA, CTIA, JVSV, PCIA, and the Electric IOUs. Several of the Opponents that wireless attachments do not pose a greater risk for pole overloading than other types of attachments. To the contrary, wireless attachments generally impose less wind load than electric utility attachments, and approximately the same wind load as
Pole Overturning Moment and Bending Moment 45-Foot Wood Pole Embedded 6 Feet in Soil per Rule 49.1-C, Table 6 4, Douglas Fir Pole) Row Forces and Moments Without PoleTop Extension With 7-Foot PoleTop Extension 1 Overturning Force 2 Feet Below Pole Top: RUS Equation 12.1 Soil Condition = Average. Soil Constant = 70 1,485 Pounds 1,259 Pounds 2 Overturning Moment at Ground Line (Safety Factor = 1.0) 54,953 Foot Pounds 55,411 Foot Pounds 3 Bending Moment of New Wood Pole at Ground Line (Safety Factor = 1.0) 90,552 Foot Pounds 90,552 Foot Pounds Before delving into the above table, we wish to acknowledge the fundamental safety issue raised by SED that a pole-top extension increases a pole’s overturning moment. We concur with the premise of SED’s proposed Rule 94.11 that a pole-top extension should not be allowed on a pole unless sufficient measures have been taken to ensure that the pole will not overturn. Rows 1 and 2 of the above table show that a 45-foot wood pole, without a pole-top extension, embedded 6 feet in average soil pursuant to Rule 49.1-C, Table 6, will overturn when a horizontal force of 1,485 pounds is applied 2 feet from the top of the pole (i.e., 37 feet above ground level), which equates to an overturning moment of 54,953 footpounds (fp.) at the pole’s ground line. Rows 1 and 2 of the above table further show that a 45-foot wood pole with a 7foot poletop extension, when embedded 6 feet in average soil, will overturn when a horizontal force of 1,259 pounds is applied 2 feet from the top of the combined
14. Arbitration Open to the Public Though participation at arbitration conferences and hearings is strictly limited to the parties that were negotiating the agreements being arbitrated, the general public is permitted to attend arbitration hearings unless circumstances dictate that a hearing, or portion thereof, be conducted in closed session. Any party to an arbitration seeking a closed session must make a written request to the Arbitrator describing the circumstances compelling a closed session. The Arbitrator shall consult with the assigned Commissioner and rule on such request before hearings begin. 15. Filing of Arbitrator’s Report Within 15 days following the hearings, the Arbitrator, after consultation with the Assigned Commissioner, shall file a Draft Arbitrator’s Report. The Draft Arbitrator’s Report will include (a) a concise summary of the issues resolved by the Arbitrator, and (b) a reasoned articulation of the basis for the decision. 16. Filing of Post-Hearing Briefs and Comments on the Draft Arbitrator’s Report Each party to the arbitration may file a post-hearing brief within 7 days of the end of the mark-up conferences and hearings unless the Arbitrator rules otherwise. Post-hearing briefs shall present a party’s argument in support of adopting its recommended position with all supporting evidence and legal authorities cited therein. The length of post-hearing briefs may be limited by the Arbitrator and shall otherwise comply with the Commission’s Rules of Practice and Procedure. Each party and any member of the public may file comments on the Draft arbitrator’s Report within 10 days of its release. Such comments shall not exceed 20 pages. 17. Filing of the Final Arbitrator’s Report The arbitrator shall file the Final Arbitrator’s Report no later than 15 days after the filing date for comments. Prior to the report’s release, the Telecommunications Division will review the report and prepare a matrix comparing the outcomes in the report to those
rendered unusable for communication conductors due to the CMRS antenna is 1 foot (i.e., the pole space between 5 and 6 feet below the power lines can no longer be used for communication conductors due solely to the installation of the CMRS antenna). Example 2: Pole Space Immediately Below Power Lines Operating at 7,500 – 50,000 Volts. The minimum safety clearance between power lines operating at 7,500 50,000 volts and a communication conductor is 6 feet. The minimum safety clearance between power lines operating at 7,500 50,000 volts and an antenna installed below the power lines is 6 feet. Thus, for power lines operating at 7,500 – 50,00 volts, it would not be possible to install a communication conductor in the first 6 feet below the power lines, with or without the CMRS antenna. In this example, for the pole between the power lines and the CMRS antenna installed 6 feet below the power lines, there is no pole space that is rendered unusable for communication conductors due to the CMRS antenna. Example 3: Pole Space Immediately Above Power Lines Operating at 750 – 7,500 Volts, Attached 6 Feet Below the Pole Top. Power lines operating at 750 7,500 volts must maintain a minimum safety clearance of 4 feet from other power lines attached to the same pole operating at 0 75,000 volts. So, if power lines operating at 750 – 7,500 volts are attached 6 feet below the top of the pole, there would enough pole space to allow another set of power lines operating at 0 75,000 volts to be attached at the top 2 feet of the pole. Power lines operating at 750 7,500 volts must maintain a minimum vertical safety clearance of 6 feet from an antenna. Therefore, an antenna