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CC SR 20201104 04 - Crest Road Utility Pole Re-Location RANCHO PALOS VERDES CITY COUNCIL MEETING DATE: 11/04/2020 AGENDA REPORT AGENDA HEADING: Regular Business AGENDA TITLE: Consideration and possible action to receive a status report on relocating certain utility poles at 3867 Crest Road. RECOMMENDED COUNCIL ACTION: (1) Receive and file a status report on issuance of an encroachment permit to relocate certain utility poles from 3867 Crest Road to across the street and onto the City right-of-way along Crest Road. FISCAL IMPACT: None Amount Budgeted: N/A Additional Appropriation: N/A Account Number(s): N/A ORIGINATED BY: Ken Rukavina, PE, Director of Community Development REVIEWED BY: Karina Bañales, Deputy City Manager APPROVED BY: Ara Mihranian, AICP, City Manager ATTACHED SUPPORTING DOCUMENTS: A. Revised Project Plans (see Attachment F) B. Original Project Plans (see Attachment F) C. Crown Castle Plans (see Attachment F) D. July 21, 2020 City Council staff report (available at: https://rpv.granicus.com/MetaViewer.php?view_id=5&clip_id=3704&meta_id= 84716 ) E. August 18, 2020 City Council staff report (available at https://rpv.granicus.com/MetaViewer.php?view_id=5&clip_id=3715&meta_id= 85594) F. October 20, 2020 City Council staff report (available at https://rpv.granicus.com/MetaViewer.php?view_id=5&clip_id=3749&meta_id= 87308) G. Portions of Tract Map 33206 (page G-1) H. SCE Costs to Underground based on original Design (page H-1) I. SCE Costs for Revised Design Presented on October 20 (page I-1) J. CSI Cost Estimate to Expand Undergrounding between Funicello’s property and the Roadway (page J-1) 1 K. CSI Cost Estimate to Prepare Undergrounding of Telecommunication Utilities (page K-1) L. Public Correspondence (page L-1) BACKGROUND AND DISCUSSION: On July 21, 2020, the City Council received a report regarding the pending issuance of an encroachment permit by the Public Works Director to allow the relocation of certain Southern California Edison (SCE) utility poles and transmission lines from the property at 3867 Crest Road to across the street within City right-of-way (Crest Road). At that time, the proposed project (Attachment B) consisted of relocating five poles and undergrounding about 270 feet of high-voltage transmission lines, leaving only 90 feet of SCE high-voltage transmission lines above ground, consisting of approximately 60 feet crossing Crest Road and 30 feet between three poles. These three poles were to be relocated by SCE. These three poles were to be within 15 feet of each other and relocated in proximity to the HOA entrance, but with appropriate tree clearance. The two remaining poles were to be relocated by the Applicants’ contractor further to the west. All transformers were to remain on the Applicants’ property side and no new transformer to be added to any of the relocated poles. The automatic re-closure switching equipment was to be installed by SCE on the middle pole of three of the five relocated poles. At the July 21 meeting, the issues outlined in the staff report were presented by Staff and discussed by the City Council, with input received from the property owners, the public and SCE (see link to the July 21, 2020 City Council Staff Report). During its presentation, Staff noted, and as confirmed by the City Attorney, that it is the Public Works Director who is charged with the authority to issue encroachment permits for such work per § 12.04.030 of the Rancho Palos Verdes Municipal Code (RPVMC). It was also noted that the City Council had requested a public discussion of the issues with all stakeholders being encouraged to present their issues, concerns, and perspectives publicly. The discussion that ensued included expressions of concern related to safety, the current state of the existing SCE poles, SCE’s response to the community’s questions, discussion of possible funding participation, and whether the RPVMC should be modified to address the scope of City Council oversight of encroachment permits involving power pole relocations. At the conclusion of the discussion, the City Council voted to continue this item to a future meeting no later than August 18, 2020 to allow Staff and the interested parties to confer one more time and to engage SCE to become a partner in the project for the betterment of the City, residents and SCE. On August 18, the City Council received a status report informing them that on August 6, a meeting with the stakeholders was held to discuss specific issues raised by the City Council and to clarify objectives of the property owners (the Funicellos) and the Rancho Palos Verdes Estates Community Association (HOA). With the general consensus of the stakeholders, the City Council agreed to continue the matter to no later than October 20, 2020 to explore other feasible alternatives for the proposed utility pole relocation project. 2 On October 20, the City Council received a status report presenting a summary of design changes to relocate five SCE poles and undergrounding approximately 380 feet of high - voltage transmission lines, leaving only 65 feet of high-voltage transmission lines above ground crossing Crest Road to one new pole on the south side of Crest Road and eliminated two SCE poles and the switching equipment west of Paseo Del Pinto. However, it was also noted that this did not eliminate the 16-kilovolt lines crossing to the south side of Crest Road, nor the need for the two additional utility communication poles on the south side of the street to accommodate Crown Castle, Cox Communications, and Frontier. The following four key issues were raised during the October 20 City Council meeting: 1. Can the utilities be undergrounded beginning on the Funicello property, including the communication lines, in order to eliminate poles on the south side of Crest Road; 2. What are the costs including to underground the project; 3. Disposition of right-of-way; and 4. Authority of the Public Works Director to issue an encroachment permit for this work. These four issues are further elaborated below. 1. Undergrounding Beginning at the Funicello Property During the City Council meeting, the HOA reiterated their desire that the SCE lines be undergrounded from the north side of the street in order to mitigate fire risks from having 16 kilovolt lines extending closer to HOA properties adjacent to the south side of the street. This matter was not able to be resolved during the City Council meeting and was partly the basis for continuing the item to this evening. A meeting was held between the Funicellos, a neighboring property owner, the HOA, SCE, Crown Castle and staff on October 26 to discuss the feasibility of beginning the SCE undergrounding on the Funicello property. SCE stated that in concept this is a potential solution, but would require the placement of a pole on the Funicello property to be used as the drop location due to needed clearance from the primary pole supporting a transformer and the transmission lines coming up the hill. The Funicellos appeared to be amenable to this design alternative if this pole can be placed at the far northeast corner of their property; however, trees and guy wire supports may be a limiting factor. Further, beginning the SCE undergrounding on the Funicello property may mean that some of the SCE conduit previously installed may be a “throw-away” cost item. There was no resolution on this matter as it was determined that a field meeting with all parties is needed to further discuss potential locations for this new pole and SCE will need to perform additional engineering analysis . Furthermore, additional costs associated with supplementary SCE engineering as well as for extending the extent of the underground construction needed to be estimated in coordination with licensed contractors. Additionally, unresolved at this meeting was who would bear the added cost for the increased undergrounding, which is discussed under Discussion Point No. 2 below. Crown Castle confirmed that the communication conduits can be placed underground, and that the costs for this work would depend on whether the conduits are placed in a 3 joint trench with SCE, or placed in their own trench either under the street pavement or within the turf in the existing easement in the Funicello’s front yard. If the communication lines are placed underground, the Funicillo’s would like the conduit to be placed in the street. Again, unresolved at this meeting was who would bear the added cost for undergrounding the telecommunication utilities which include Crown Castle, Cox Communication, and Frontier. 2. Costs At the October 20 meeting, a member of the HOA Board indicated that there may interest in providing funds to fully underground both the SCE and communication lines, but no commitments have been or can be made by the HOA at this time. The HOA’s willingness to contribute depends on whether or not there are poles ultimately placed on the south side of Crest Road and what the total magnitude of costs w ill be. Full HOA financial support cannot be garnered or committed without conducting a legally noticed HOA Board meeting where all HOA members are notified and allowed an opportunity to vote, which has not yet occurred. In response, the City Council requested that the Funicellos share the undergrounding costs with City Staff and the HOA. As requested, Mr. Funicello provided costs for the following: • SCE Costs to Underground based on original Design (Attachment H) - SCE costs to the Funicello’s for the original design and construction, plus the costs to develop the re-engineered plans totals $453,464.96 (Attachment H). This cost excludes communication line relocation design and construction costs that will be charged by Crown Castle and other utilities, and excludes the retaining wall and building pad required by SCE for above-ground equipment. • SCE Costs for Revised Design Presented on October 20 (Attachment I) – SCE costs for the design presented to the City Council at the October 20 meeting is approximately $340,000 which includes the design cost, of which the Funicello’s have paid approximately $320,000 to SCE (the remaining balance is approximately $20,000). The Funicellos are in the process of obtaining costs from licensed contractors to perform the additional undergrounding described in No. 1 including undergrounding the telecommunication utilities. At this time, the Funicellos have provided a cost estimate from one contractor, CSI Services, in the amount of $90,200 (Attachment J). The scope of work includes traffic control, undergrounding raceway for SCE, street trench, installing pipe, backfill, asphalt patch work, and permits. Additionally, CSI Services provided a separate cost estimate, in the amount of $12,700, to prepare the trench f or the undergrounding of telecommunication utilities (Attachment K). As reported at the October 20 meeting, the utility companies will assess costs to insert the lines. Crown Castle indicated a cost of approximately $25,000 (outstanding cost estimates from Cox Communication and Frontier are pending but are anticipated to be approximately the same cost as Crown Castle). 4 The Funicellos are in the process of obtaining two addition cost estimated from licensed contractors which will be provided to the City Council and the public as late correspondence in advance of the November 4 meeting. 3. Disposition of Right-of-Way As stated in previous staff reports, the City Attorney’s office has opined that the south side of Crest Road west of Paseo Del Pinto is public right-of-way. Notes Page 1 of Tract Map No. 33206 clearly delineate the scope of the City’s legal interest in Crest Road adjacent to the HOA’s tract. Attachment “G” includes enlarged portions of the Tract Map No. 33206, which delineates the scope of the City’s legal interest in Crest Road adjacent to the HOA’s tract. We call your attention to the first, second and third sentences in the dedication by the Developer. Sentence one certifies that the Developer is the owner of the real property within the subdivision which is thereafter detailed on the various pages of the Tract Map. (Attachment “G,” Los Angeles County Recorders Book 930, page 53.) Sentence two provides that the developer dedicates to the City a strip of land “for sanitary sewer, road maintenance, public utilities, storm drain and storm drain ingress and egress, and public pedestrian access purposes so designated on said map and all uses incident thereto including the right to make connections therewith from any adjoining properties.” This area runs along the interior portion of the Tract boundary. (Attachment “G,” Los Angeles County Recorders Book 930, pages 53-54 & 56; emphasis added.) Sentence three confirms that the developer acknowledges “[a]s a dedication to public use . . . all of Crest Road within or adjacent to this subdivision remains a public street, we hereby abandon all rights of direct vehicular ingress and egress from abutting lots to the said street.” (Attachment “G,” Los Angeles Recorders County Book 930, pages 53- 54 & 56; emphasis added.) This sentence acknowledges that Crest Road was a public street prior to this dedication and confirms that Crest Road continues to be a public street after the dedication. Public rights-of-way are exclusive meaning the City has exclusive control of the road and the underlying fee owner may not control the use of the land. The rule is that a City has the right to use of a dedicated street and this right is paramount to the rights of abutting owners regardless of whether they own the fee to the c enter of the street or not. Accordingly, unless vacated, the underlying owner does not have any rights other than as an abutter meaning the owner has a right to access the Crest Road from one access point designated on the Tract Map. Therefore, the City Attorney’s office remains of the considered legal opinion that Tract Map 33206 specifically confirms that the City has an exclusive right -of-way in that portion of Crest Road “adjacent” to the HOA’s tract. The HOA has no right, title, or interest in that portion of Crest Road unless or until the City abandons its right-of-way. 5 The right-of-way measures 100’ in width, 50’ on either side of the center line, and includes the improved roadway and unimproved land.1 However, assuming, for the sake of argument only, that the forgoing language of dedication could be deemed to be ambiguous (which it is not) such that the Tract Map provides for an inconclusive dedication, the City still has an prescriptive right -of-way in and over Crest Road because the road has been used by the general public for decades and because the City maintains the same. Therefore, pursuant to Civil Code § 1009, the City, long ago, acquired a prescriptive right -of-way over Crest Road.2 Implementation of the proposed relocation of SCE power poles and power lines would be entirely within the City’s Crest Road right-of-way as a privately funded project (Rule 20C) to relocate public utilities which has been approved by SCE and is now subject only to the issuance of an encroachment permit by the Public Works Director. 4. Public Works Director Authority to Issue Encroachment Permits to the Funicello’s Contractor Encroachment permits are issued pursuant to Chapter 12.04 of the Rancho Palos Verdes Municipal Code (“RPVMC”). Specifically RPVMC § 12.04.030 vests in the Director of Public Works “all powers duties and responsibilities of the road commissioner of the county [of Los Angeles] with respect to permits, inspections, work, administration or otherwise relating to construction, excavations or encroachments in city streets . . . are transferred to and vested in the director of public works of the city.” (Emphasis added.) The County of Los Angeles Road Commissioner has such powers to issue encroachment permits as set forth in Chapter 16.08 of the Los Angeles County Code (“LACC”). Commencing with Section 16.08.010 the LACC specifies the contents of an application for a permit and advises that “[t]he commissioner [or in the case of the City, the Director of Public Works] may make such changes or additions in any application for a permit as in his opinion are necessary for the protection of the highways, for the prevention of undue interference with traffic, for the safety of persons using such highways, as to the route over which to move any over height, width, length or weight 1 Moreover this100-foot right-of-way (50 feet on each side of the center line) exists around the tract up to about Paseo Del Pino. From Paseo Del Pino westward the south 50 feet is confirmed to be a public street; the north 50 feet is designated a private street. However, that designation is no longer legally valid because, as noted below, the City certainly has acquired a right-if-way in this so- called private street by prescriptive easement. (See, note 3, below & Civil Code § 1009(d).) 2 Civil Code § 1009(d) provided that: “Where a governmental entity is using private lands by an expenditure of public funds on visible improvements on or across such lands or on the cleaning or maintenance related to the public use of such lands in such a manner so that the owner knows or should know that the public is making such use of his land, such use, including any public use reasonably related to the purposes of such improvement, in the absence of either express permission by the owner to continue such use or the taking by the owner of reasonable steps to enjoin, remove or prohibit such use, shall after five years ripen to confer upon the governmental entity a vested right to continue such use.” 6 load; as to the location, depth, dimensions, character and number of excavations; as to encroachments made or placed . . . .” The Director of Public Works may also “establish additional requirements for the work to be done under the permit, including equipment to be used, type of backfill, compaction, paving, traffic regulations, hours of work, flagmen, lights, inspection, and other similar requirements. He also may require whatever advance notice he deems proper for requests for inspection,” and “require the permittee to make proper arrangements for and bear the cost of the relocation of any structure, publicly owned facility, tree or shrub where such relocation is made necessary by the proposed work for which a permit is issued.” (LACC §§ 18.08.050 & .060.) Finally, the Director of Public Works has authority to “require that evidence be submitted with the application to satisfy him that the proposed overhead structure or encroachment will not, insofar as he can foresee, create a hazard of any kind.” If the foregoing requirements are satisfied, the Public Works Director “may issue to the applicant a written permit to perform the work set forth in the application. The commissioner may refuse to issue a permit if he finds that it is not in the best interest of the general public to do so.” (LACC §§ 18.08.070 & .080.) CONCLUSION: Issuance of the encroachment permits was conditioned on the City being reimbursed the cost to replace the trees illegally cut down by the Applicants’ contractor. That payment has been rendered to the City (Attachment L). Having now carefully reviewed all aspects of the application for the encroachment permits, City Staff and the City Attorney are of the opinion that the encroachment permits to relocate certain SCE utility poles combined within undergrounding of high-voltage lines can be issued once there is resolution on location of poles, extent of the undergrounding, and who will pay for any additional costs. Although it was the City’s intent to use the time between the July 21 meeting and now to develop a mutually agreeable design for the proposed project between the various stakeholders, because this is a privately funded project with limited permit authority by the City, the ultimate design and related costs is between the Funicellos, SCE and telecommunication utilities (i.e. Crown Castle). Recently, the HOA has indicated it may consider providing funds to further underground the project beginning on the Funicello’s property, but no commitments have been or can be made by the HOA at this time unless costs are known and can be considered by the HOA. Staff will continue to facilitate a design and funding compromise and then issue encroachment permits accordingly once reached. However, if there is an impasse to the full undergrounding due to costs and who pays, and location of infrastructure, the Public Works Director will issue encroachment permits based on the re-engineered design, as the Office of the City Attorney has independently considered the various objections to the issuance of encroachment permits and is of the considered legal opinion that there is no legal impediment to the Public Works Director issuing the requested permits. 7 ALTERNATIVES: In addition to the Staff recommendation, the following alternative action is available for the City Council’s consideration: 1. Identify additional issues or concerns, provide direction to Staff, and continue this item to a future agenda. 8 G-1 Utilities easementPublic streetG-2 Public streetUtilities easementG-3 Utilities easementPublic streetG-4 G-5 H-1 H-2 H-3 H-4 I-1 I-2 I-3 I-4 I-5 I-6 I-7 I-8 State License # 959577 (Class A, B, C10) Construction Division PO Box 271 San Pedro, CA 90733 Fax No.: 310.530.8110 Bill To: Gian Carlo Funiciello 3867 Crest Road Rancho Palos Verdes, CA 90275 Ph. Cp. gcfsportsmgmt@aol.com SCOPE OF WORK: INCLUDES: - Traffic Control - Underground Raceway for Edison - Street Trench - Install Pipe - Backfill - Asphalt Patch - Permits CSI appreciates the opportunity to provide you the following price. Please contact the undersigned with any questions, Regards, CSI Services Frank Colaruotolo (310) 628-1099 Installation of Approximately 120ft of 5inch Conduits T O T A L 90,200.00$ Quantity Description Net 30 CONDUIT INSTALLATION - 3867 Crest Road, Rancho Palos Verdes, CA 90275 P. O. No. Terms PROPOSAL Project 10/27/2020 Number: CSI-2007 Date:C S IS e r v i c e s J-1 State License # 959577 (Class A, B, C10) Construction Division PO Box 271 San Pedro, CA 90733 Fax No.: 310.530.8110 Bill To: Gian Carlo Funiciello 3867 Crest Road Rancho Palos Verdes, CA 90275 Ph. Cp. gcfsportsmgmt@aol.com SCOPE OF WORK: INCLUDES: - CSI appreciates the opportunity to provide you the following price. Please contact the undersigned with any questions, Regards, CSI Services Frank Colaruotolo (310) 628-1099 T O T A L 12,700.00$ Installation Concurrently 2- 4inch Conduits for Low Voltage Systems Installation Concurrently 2- 4inch Conduits for Low Voltage Systems Quantity Description Net 30 CONDUITS FOR LOW VOLTAGE SYSTEMS - 3867 Crest Road, Rancho Palos Verdes, CA 90275 P. O. No. Terms PROPOSAL Project 10/27/2020 Number: CSI-2008 Date:C S IS e r v i c e s K-1 1 Ken Rukavina Subject:FW: Follow Up Request for Clarification in Staff Report From: Kathy Campbell    Sent: Thursday, October 15, 2020 3:10 PM  To: Ara Mihranian <AraM@rpvca.gov>; Ken Rukavina <krukavina@rpvca.gov>  Subject: Follow Up Request for Clarification in Staff Report Dear Ara and Ken, 1. Please include the forwarded correspondence below and clarify and address these questions from the Oct. 20 Staff Report: 2. Please clarify the statement on Page 6, under " Conclusion": " Issuance of the encroachment permits was conditioned on the City being reimbursed the cost to replace the trees illegally cut down by the Applicant's contractor. That payment has been rendered to the City"(underlining in original). 1. What was the amount of the payment? $1,708.oo 2. What was the date of the payment, who paid, and who was the payee? Check date - June 28, 2020, paid by - Funiciello, payee – City Where were those funds deposited? Not deposited yet 3. What process was used to determine the amount of the payment? The cost of tree replacement was based on an estimate from a nursery 3. Condition 12 of the May 6 2019 Crown Castle permit provides: "All shrubs, plants, trees or parkway improvements that have been damaged or disturbed during "in the course of the work shall be replanted or replaced so as to restore the work site to original condition or better". Was this condition fulfilled? The work was stopped which included the referenced note # 12 on the Crown Castle Plans. Prior to closing out this permit this condition will be required to be completed. Will it be enforced before any new permit issues? Work associated with the permit was stopped, the permit has not been canceled. Work like noted through condition #12 would require completion prior to canceling the permit. Thank you, Kathy Campbell -------- Forwarded Message -------- Subject: Crest Road Utility Relocation Date: Wed, 30 Oct 2019 22:10:48 +0000 L-1 2 From: Elias Sassoon <esassoon@rpvca.gov> To: Kathy Campbell >   Hi Kathy: Thanks for reaching out to us. My comments are below in blue.   Regards,   Elias K. Sassoon, Director Department of Public Works City of Rancho Palos Verdes 30940 Hawthorne Blvd. Rancho Palos Verdes, CA 90275 Tel: 310‐544‐5335 Fax: 310‐544‐5292     From: Kathy Campbell <>   Sent: Wednesday, October 23, 2019 11:20 AM  To: Elias Sassoon <esassoon@rpvca.gov>  Subject: Crest Road Utility Relocation Dear Elias, Thank you for meeting with me to address concerns regarding the numerous ongoing irregularities in the permitting process for this illegal project on Crest Road. I appreciate that the City shut down this project. The concerns which were initially raised 4 months ago with the City continue unresolved. Those concerns are amplified after reviewing the most recent application for encroachment permit filed on Oct. 14, 2019 by Art Franco of SCE as the Applicant/Permittee. I will briefly summarize the concerns we discussed below. 1. I understand the City has collected the fine imposed for the initial, now expired permit, issued by the City to Crown Castle Utility for work exceeding the scope of the permit. In reality, the work performed bears no resemblance to that permit. Your understanding is correct. 2. 2. The pending Application by Applicant SCE makes no provision for replacing trees or vegetation damaged by the contractor by the illegal entry onto HOA property. The City has represented that no further permits would be issued until this issue is resolved: “The contractor is shut down and won’t be able to proceed till such time they submit a plan as to how they intend to mitigate the removal of trees/vegetation….” This is going to be a comment from us to SCE regarding this application. L-2 3 3. 3. SCE has admitted that this is not an Edison project, and that they did not order the removal of the trees or vegetation “John Collins (the City of RPV inspector) and I (Elias) met with Frank Colaruotolo of CSI Services (the Contractor) and Jerry Hollerup of SCE at the site this morning about 9:30 AM and discussed this incident. The contractor accepted the full responsibility of what has taken place and admitted the removal of the trees/shrub was NOT directed by SCE. We measured the calipers of the removed trees which added up to 96 inches. A few shrubs were also taken out.” On June 25, 2019, Devan Doherty confirmed on site that these trees were not removed by Edison or as part of an Edison project. See my response to paragraph 2. 4. 4. SCE does not have the authority to remove the trees or vegetation prospectively because currently there are no overhead wires passing through trees- CPUC GO 95 does not apply. Please see my response to 2 above.   5. 5. The fact that the Applicant/Permittee is SCE, who is not the property owner in this customer driven request, raises questions. Edison has explicitly stated that this is not an Edison project, and is not the proper Applicant, as it is not the owner of the property, easements, “future easements” or property “to be deeded”, per the Application. It is our understanding that SCE’s application is submitted to us on behalf of the property owner. 6. 6. SCE needs to establish that this work is being done in a public right of way and that it has the proper easements to proceed with this project. I believe SCE understands that very well.   7. 7. I have personally reviewed 4 maps from the County assessor’s office going as far back to 1946, which show that Crest Road is a street of variable width, and that the south western portion of Crest Road past Paseo de Pino is a PRIVATE street, 50’ wide. Pls send me copies of document/drawing which supports your notion. The documents which you sent me a few weeks ago had nothing to do with Crest Road, and I informed you of that a day after you sent those documents to me. Again, if you have any other document that shows this stretch of Crest Road is a “Private” street, please forward this document to me as soon as you can. 8. 8. The City claims a 100’ right of way over Crest Road. Please provide the language of conveyance or dedication that creates this claimed right of way. Tract map filed Please see attached map. 9. 9. SCE’s own rules- Rules 15 [Distribution Line Extensions] and 16 [Service Extensions] , explicitly referenced in the Applicant’s submitted plans, in addition to Rule 20 [Undergrounding],do not permit this work to be done. [This customer driven project does not involve either new construction or a change of use or occupancy as defined in state or local law.] We are NOT able to opine on SCE’s rules or their enforcement.   10 10. “Order of Operations”- This customer driven project to facilitate the installation of a swimming pool, requires first, that plans be submitted to planning/community development, so that the required L-3 4 “change of use or occupancy” is obtained. Is the City going to issue a permit for a swimming pool in a front yard? Can all the City setback requirements be met? SCE ‘s own Transmission Line Right of Way Constraints and Guidelines prohibit installation of permanent structures, including swimming pools..This application needs to be processed as submitted.   1111. After 2010, the CPUC and SCE Above Ground Equipment Initiative, [“AGE Rule”] explicitly recognizes the municipality’s authority to impose conditions for work occurring in the public right of way. Please see response to 9 above.     1212. SCE does not have the authority to favor one ratepayer over another, and may not shift the burden from one private property owner to another without notice or due process in violation of federal and state law and local ordinances. See response to 9, above. 1313. In any case, a right of way for “public use” does not contemplate a customer-driven request for private benefit. We will be reviewing this issue. 1414. The Safety Review- This proposed relocation of utility poles from open space into a grove of mature pine trees creates an immediate public health and safety issue, and contradicts the City’s wildfire mitigation plan, as described in the City’s November 5, 2018 letter to the CPUC. Furthermore, the proposed relocation of utility poles from one side of the level street onto a upward slope creates the exact condition as the Pacific Palisades fire of October 21.2019- fire travels uphill quickly, without the “safety buffer” created by Crest Road. As I have indicated earlier, as part of this application most of the existing high voltage cables is planned to be undergrounded and consequently it will be safer. 1515. Fundamental Fairness. As we discussed, it appears that there has been, and continues to be, a deliberate attempt to avoid a public hearing and “work around the rules” by “finessing” the process and rules of the City, CPUC and SCE. Everyone benefits from transparency. Please enforce the rules. Public Works has been transparent and proactive regarding this project. We follow the permit procedures as they exist in the code. Respectfully and in Good Faith, Kathy Campbell L-4