Pacific Gas and Electric's Revised Undergrounding Plan: AT&T's Concerns and Recommendations

Strategic Insights -

AT&T has submitted a Sur-Reply Brief in response to Pacific Gas and Electric's (PG&E) revised plan to underground thousands of miles of its overhead power lines for wildfire mitigation purposes. The document highlights AT&T's concerns regarding the uncertainty surrounding PG&E's proposal and its potential impact on other parties, including broadband and communications providers.

Key Takeaways:

  • PG&E has revised its proposed undergrounding plan to cover 2,000 miles of overhead lines, from the original 3,358 miles, at a cost of $6 billion, down from $10 billion.
  • Despite the revised scope, PG&E's plan still lacks detail on the "what, where, when, and how" of the potential undergrounding, which is projected to cover thousands of miles.
  • The revised proposal provides no more certainty to pole attachers about the specifics of the program, including how often PG&E will only underground the secondary wires and leave its existing poles in place for other pole attachers' facilities.
  • AT&T's facilities do not pose a fire-ignition risk, and the Commission should waive or reimburse costs imposed on broadband and communications providers in connection with PG&E's wildfire mitigation efforts.
  • PG&E's revised plan does not alleviate the need for a separate rulemaking to address the costs of communications providers being forced to underground communications facilities as a result of electric utilities' wildfire-mitigation undergrounding.
  • The Commission should direct that any costs imposed on broadband and communications providers in connection with PG&E's wildfire mitigation efforts be waived or reimbursed by PG&E.

Statistics:

  • PG&E has reduced the proposed undergrounding miles from 3,358 to 2,000 miles.
  • The revised plan is expected to cost $6 billion, down from $10 billion.
  • Assuming an average of 35 poles per mile, PG&E's revised plan would affect 70,000 poles.
  • AT&T estimates that the cost of buying those poles at an average cost of $1,000 each would be $70 million.
  • If AT&T had to underground its own facilities across 2,000 miles at an average cost of $1 million per mile, the cost would be $2 billion.

Sources:

  • Application No. 21-06-021 SUR-REPLY BRIEF OF PACIFIC BELL TELEPHONE COMPANY D/B/A AT&T CALIFORNIA (U 1001 C)
  • D.18-12-021, Application of California-Am. Water Co. (U210w) for Authorization to Increase Its Revenues for Water Serv. by $34,559,200 or 16.29% in the Year 2018, by $8,478,500 or 3.43% in the Year 2019, & by $7,742,600 or 3.03% in the Year 2020, (C.P.U.C. Dec. 13, 2018) (A.16-07-002)
  • D.01-12-009, Interim Opinion Revising the Rules for Converting Overhead Lines to Underground at 26 (Cal. P.U.C. Dec. 11, 2001)