meeting safetyfactor requirements. To ensure accurate load calculations, SED’s proposed Rule 94.3D would require the specifications” of all pole “actual 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
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
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