Utility Pole Safety and Hazard Evaluation Approaches (2020)

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61 Relative to utility pole safety, the federal regulation at 23 CFR 645.209(k) (CFR 2011) reads as follows: When the transportation department determines that existing utility facilities are likely to be associated with injury or accident to the highway user . . . the highway agency shall initiate . . . in consultation with the affected utilities, corrective measures . . . According to FHWA guidance in its program guide (FHWA 2003), the intent of this regula- tion is for each STA to work with the relevant UOs to reasonably and cost-effectively develop and implement programs to systematically remove, relocate, or mitigate hazardously located utility poles. As envisioned in the federal regulation, a utility pole crash-reduction program should contain the following essential elements: • Identification of utility poles in hazardous locations • Analysis of hazardously located poles and development of countermeasures • Establishment of a goal for removing, relocating, or mitigating utility poles situated in hazardous sites • Actual removal, relocation, or mitigation of hazardously located utility poles. Once specific corrective actions are identified, the state or local agency expects that imple- mentation will be pursued through a prioritization process that takes into account available resources, planned replacement and upgrading for both utility and highway physical plant, and overall crash-reduction potential. To be effective, this corrective program must be undertaken as a joint effort by the high- way authorities and the affected utilities. UOs working closely with their respective STAs can produce an effective process for identifying problem areas and establishing schedules for corrective actions. Wherever possible, such schedules should take into consideration each UO’s planned activities, online upgrades, replacements, and other relevant concerns. The preferred approach to a corrective program includes an orderly, planned, and effective process of safety improvements over time that would take into account the costs to both the highway user and the utility consumer. In accordance with these regulatory constraints, most STAs have established policies for locating new utility poles within highway rights-of-way. Appendix D details the current FHWA guidance on utility pole policies. Appendix E includes examples of state activities for treating utility pole and tree safety problems, as taken from the FHWA report on best practices (Jones 2016). Although most STAs have established policies for locating new utility poles within highway rights-of-way, only a few STAs have adopted policies to address existing utility poles in high-risk locations. C H A P T E R 9 STA Case Examples

62 Utility Pole Safety and Hazard Evaluation Approaches The rest of this chapter discusses efforts by the Washington State DOT, Georgia DOT, New Jersey DOT, North Carolina DOT, and an anonymous DOT to improve the safety of existing utility poles in high-risk locations. Washington State DOT Washington State DOT (WSDOT) policies for utility pole placement and safety are directly shaped by its utility accommodation practices. Utilities are authorized to occupy state highway rights-of-way under franchises with a 25-year term. In the case of poles, placement and design must comply with the standards in effect at the time of the installation or franchise renewal. As it happens, a significantly large number of franchises for utility poles are temporally clustered so that their respective 25-year terms expire within a few years of one another. This mass expiration of franchises and the ensuing scramble for renewals results in large numbers of poles that no longer comply with WSDOT control zone standards because of either changed design require- ments or modified highway characteristics. When large numbers of franchises expire within a similar time frame, the affected utility companies are often surprised to learn that renewal will require significant unanticipated capital investment to correct control zone deficiencies. Such companies seek to work with WSDOT to limit the extent of actual relocations. For its part, WSDOT recognizes that utility companies have limited funding available for control zone mitigation and that the public interest lies in focusing funding to maximize safety benefits. As part of the ensuing coordination, WSDOT then reexamines its policies to consider incorporating new approaches and innovations that may lend themselves to the current conditions. Between 1989 and 1991, during one of the mass renewal periods, WSDOT updated its policy to adopt a “cost-effective selection procedure” as a tool to justify alternatives to relocation, and imple- mented an “annual mitigation target” program for utilities to address compliance according to an annual plan. This approach relieved utility companies of the need to address all noncompliant poles in a short time period. The next major control zone policy revision occurred in 2014—not coincidentally, 25 years later. WSDOT’s latest policy revision combines its system to categorize poles (into one of three risk location categories) and RSAP-V3. As long as poles are categorized as Location II (not high risk), have no record of being struck, and fall below a certain designated risk threshold (via RSAP-V3), they may remain in place for a new 25-year franchise term, thus allowing the utility to target locations where this combination of conditions is not achievable. Utility objects are classified as WSDOT Location I, II, or III objects as follows: • Location I objects include aboveground fixed (unyielding, non-traversable) utility objects located within the control zone (1) outside of horizontal curves where the advisory signed speeds for the curve are 15 mph or more below the posted speed limit of that section of highway; (2) within the turn radius area of public grade intersections; (3) at sites where a barrier, embankment, rock outcropping, ditch, or other roadside feature is likely to direct a vehicle into a utility object; and (4) within 5 feet horizontally beyond the edge of the usable shoulder. • Location II objects include all fixed utility objects positioned within the control zone that are not classified as Location I or III objects. • Location III objects include fixed utility objects, located either outside the control zone or in the control zone, that are mitigated by an alternative countermeasure (e.g., sited in inacces- sible areas, shielded, or constructed as a breakaway).

STA Case Examples 63 The WSDOT utility object relocation effort generally requires that (1) new utility objects must be placed outside the control zone; (2) existing utility objects must be moved or mitigated in conjunction with highway construction or reconstruction projects; and (3) other existing utility objects must be repositioned or mitigated systematically. The state supplies additional information about the WSDOT objective of eliminating utility object collisions in accordance with Washington State’s Strategic Highway Safety Plan (Washington State DOT 2010) and offers guidance on the placement of aboveground utilities within WSDOT highway rights-of-way in Chapter 9 (Control Zone Guidelines) of the WSDOT Utilities Manual M 22-87 (Washington State DOT 2019). Georgia DOT Georgia has an active utilities coordination program, the Utility Pole Safety Program. The impetus for this program is the Georgia Utilities Coordinating Council (GUCC). Through its more than 35 chapters in seven regions of the state, the GUCC provides an overall cooperative process to exchange information and resolve conflicts in the utility and public sectors. It also maintains standing and ad hoc committees to address mutual issues, including the Clear Road- side Committee, which is composed of members from the Georgia DOT (GDOT) and from the aerial UOs (i.e., electrical, telecommunications, and cable television industries). Recognizing the disproportionate number of utility pole crashes in Georgia and other south- eastern states, the Clear Roadside Committee initiated efforts to improve policies for placing utility poles along public rights-of-way in Georgia. This work involved developing a plan to relocate as many potentially hazardous utility poles as possible to a safer distance from the travel way or to meet clear zones on U.S. and state routes. This plan was created by identifying critical roadway sections based on prior crash history and prioritizing these areas for mitiga- tion. FHWA recognized this innovative effort in 1998 with its presentation to the GUCC of the Best Overall Operational Improvement Biennial Safety Award. The current Utility Pole Safety Program assesses crash data every 2 years to program the projects as safety funds become available. By consensus, the Clear Roadside Committee recognizes U.S. and state routes as the most critical. GDOT’s Traffic Operations Section prepared a report documenting crashes involving utility poles during a consecutive 3-year period and based on 3-mile stretches of road. The routes were prioritized based on the total number of crashes (not just fatal crashes) and the feasibility of pole relocations. Not surprisingly, most of the identified sites were in metropolitan areas, with the top 10 ranked sites, historically, in the metropolitan Atlanta area. However, as more funding becomes available, the Clear Roadside Committee plans to expand the program into other areas of the state. Clear Roadside Committee recommendations for pole relocations can range from moving the poles a few feet in certain urban low-speed areas to as much as 30 feet in some rural areas. After route selection, the stakeholders meet in the field to walk the route and determine which poles to relocate and how far back the poles can be moved. In addition, during such field checks, other factors may become evident that would make a pole ineligible for relocation, e.g., absentee property owners, proximity of underground utilities, historic trees, endangered species, and Americans with Disabilities Act (ADA) factors. Because the Georgia active utilities coordination program does not allow the purchase of any rights-of-way, all poles are relocated within the existing right-of-way footprint. In some cases, the pole owner will seek additional easements to accommodate the proposed relocations. In addition, the projects must obtain certifications and clearances from the Office of Environmental Services and the Office of Right-of-Way.

64 Utility Pole Safety and Hazard Evaluation Approaches On a typical project, the aerial UOs enter into a split-cost (50-50) force account agreement with GDOT for performance of the work. Reimbursement criteria in Chapter 4 of the GDOT Utility Accommodation Policy and Standards (Georgia DOT 2018) read as follows: Projects shall be identified and programmed based on crash data and other traffic data to indicate there will be a high probability of measurable results benefiting the traveling public. Projects will normally require at least 50% participation from the utilities toward the in-kind replacement cost. Costs including right-of-way, engineering and administration of the in-kind relocation cost may be counted toward the Utility’s share whether included in the agreement or a separate estimate to support the Utility’s contribution to the project. The Utility may upgrade its facility in conjunction with the work but any costs attributable to the upgrade shall not be counted toward the minimum share to be borne by the Utility. As of April 2019, five Clear Roadside Committee projects had been undertaken in Metro Atlanta. Two are complete; one is nearing completion; one is midway through the work; and one just began. The two completed projects apparently have had a very positive effect on their surroundings—the areas have improved and been regenerated. These successes reiterate the need to continue studying pole safety and to plan for mitigations that achieve a positive impact on communities over time. Successful implementation of pole relocation projects necessitates coordination and coopera- tion from multiple entities so that work is completed efficiently. Once the pole owner (typically an electric provider) has relocated its targeted facilities, it becomes especially critical for other stakeholders to relocate and adjust their infrastructures in a timely fashion. Over the years, GDOT has seen more non-utility infrastructure (e.g., traffic signal interconnects, cameras, wireless telecommunications equipment, license plate readers) attached to utility poles. In urban areas, ADA accessibility must be incorporated before, during, and after construction, and buried utilities that may conflict with pole relocations also must be considered. Additional information about the GDOT Utility Pole Safety Program is supplied in Chapter 8 of the GDOT Utility Accommodation Policy and Standards (Georgia DOT 2018). New Jersey DOT Gabler, Gabauer, and Riddell (2007) investigated New Jersey’s experience with utility pole crashes and collisions based on New Jersey crash records from 2003–2005 and on FARS data for 2000–2004. They found that each year in New Jersey, approximately 10,000 vehicle occu- pants were in crashes involving utility pole impacts. With this in mind, the New Jersey DOT (NJDOT)—in conjunction with researchers Gabler, Gabauer, and Riddell (2007)—developed the Utility Pole Mitigation Program (UPMP) to identify and improve utility poles in the highest- risk crash locations. They selected 20 sites for mitigation that were not part of any active design or construction effort. The UPMP included a pilot project on the use of energy-absorbing poles at some locations. These poles differed in many ways from their breakaway counterparts made of wood and steel. The energy-absorbing hollow poles featured composite construction consisting of filament- wound fiberglass-reinforced polyester. These poles were 45 feet long, with a wide octagonal cross-section on the lower portion that transitioned to a narrow circular cross-section near the top. The poles were designed to collapse and to elongate upon impact (as opposed to breaking away and potentially falling into traffic). Gabler, Gabauer, and Riddell (2007) observed no excessive occupant risk factors in either of two separate crash tests. While NJDOT initially encountered hesitation from the utility companies invited to par- ticipate in the UPMP, continued outreach eventually produced an agreement for replacing and installing fiberglass poles in accordance with the policy when possible.

STA Case Examples 65 Composite poles offered several advantages over traditional wooden poles in terms of weight, service life, and maintenance. For example, composite poles weigh 475 pounds while wooden poles come in at 1,000 pounds; the service life for composite poles is 80 years with consistent perfor- mance, but the service life for wooden poles totals only 20 to 50 years, with declining performance; and composite poles have no maintenance requirements, but wooden poles must be maintained every 5 to 7 years. North Carolina DOT When the North Carolina DOT (NCDOT) determines that an existing utility facility represents a potential hazard or poses an unacceptable risk to highway users, NCDOT consults with the affected utility and initiates corrective measures that will provide a safe highway envi- ronment. Available corrective measures include changes to the utility or highway facilities; such measures are prioritized to achieve maximum safety benefits in the most cost-effective manner. Corrective measures are managed as a joint effort between the utility and NCDOT to identify problem areas and establish mitigation schedules. Whenever possible, these schedules take into consideration both utility and NCDOT planned activities, upgrades, and replacements to create an orderly and effective process for safety improvements. Exceptions to the NCDOT policy are allowed if the UO can demonstrate that extreme hard- ships or unusual conditions justify the exception and that alternative measures can be under- taken to fulfill the intent of the policy. The response to a request for exception includes an evaluation of the design, environmental mitigation, safety, and economic effects that would result from granting the exception as well as a consideration of any other pertinent information. Anonymous DOT One anonymous STA started negotiations in the late 1990s with the utility industry to improve pole safety. The utilities advocated a voluntary system to remove poles from strategic locations, envisioning that a targeted approach would produce the best improvements to safety. The STA pulled crash data to identify these strategic locations, which demonstrated that the greatest impact would be on conflict points (such as intersections, driveways, and auxiliary lanes). These areas were identified as “control zones” in a series of drawings. Utilities would not be prohibited from the control zones, but the utility would be expected to voluntarily relocate poles according to new construction criteria rather than, as they historically did, keeping the poles in place per federal-aid non-freeway criteria for resurfacing, restoration, and rehabilitation (RRR). However, in the next couple of years, the utility companies voluntarily relocated such poles in only a few cases, arguing that they were not legally obligated if the pole had not been hit while meeting RRR criteria and that the STA could not claim that the pole constituted a safety issue under those conditions. The data were not sufficient for that type of analysis, so it was just a qualitative judgment that additional offset in the control zone (sometimes as little as 1 to 2 feet) would produce some tangible safety improvement. Subsequently, the department decided that voluntary compli- ance was insufficient and asserted that it should have the authority to order poles to be relocated outside of the control zones. Because new construction projects already held the poles to the new construction criteria, the control zones were applied only to poles in RRR construction projects. The STA started rulemaking to add control zones requirements to its new utility guidelines. The utilities balked because this approach had progressed far beyond the idea of voluntarily and cooperatively improving safety, as they initially agreed to do. The most critical utility poles were located in control zones. These poles handled multidirectional aerial crossings and were already

66 Utility Pole Safety and Hazard Evaluation Approaches optimally sited in many cases. Thus, the utilities were facing the possibility of the state ordering the relocation of pole utilities underground or off of rights-of-way without any crash history. Worried that this would set an unacceptable precedent, UOs demanded a way to evaluate each location to prevent unnecessary relocations. Furthermore, the utility industry would concede to this new rule requirement only if it were truly that important to safety. Moreover, the utilities argued that if the control zone requirements actually were that central to safety, surely the STA would impose the same requirements on its own aboveground objects. Therefore, to preserve the STA’s authority to order the UOs one day to move poles located in control zones to sites off the rights-of-way or to bury the lines underground, other obstacles in the STA’s control zones would need to be moved as well. The STA then adopted new utility guidelines for control zones, including an exception process. Over the next decade, the STA received and approved more than 125 exceptions for control zones. In all instances, the requests were resolved to the satisfaction of the STA and the utilities through an evaluation of how the permitting was performed, the project type, and the crash history. Never once was a utility ordered to take its poles off the right-of-way or bury the lines underground. During the process of considering control zones, STA officials determined that the STA cannot order a UO to relocate a pole off the right-of-way or to run lines underground because of a control zone violation. In addition, the STA did not want to hold all roadside features to the control zone requirements. Furthermore, the data were not sufficient to justify the control zone requirements, and the department could not quantify the benefits of using control zones. Thus, the previously discussed documentation for the exception process apparently did not provide any real protection or benefit. STA officials also decided that enforcement of control zones for utility poles added to the expense, effort, and complexity of a project. Furthermore, employing control zones seemed to be a source of constant confusion and frustration for all participants. Based on these experiences, the latest guidelines incorporated an evaluation process for any pole within RRR construction project limits that had a crash history and no longer met control zone criteria. During the last 10 years, all newly permitted utility pole lines were placed according to the STA’s “new construction requirements.” For rural areas, the requirement called for installing the poles not only as close to the right-of-way line as practical but also outside the clear zone. For urban areas, the poles were required to be as close to the right-of-way line as practical but no closer than 4 feet from the face of curb. This requirement applied in all cases: during new construction, during RRR projects, during a reconstruction project, or in the absence of an ongoing project. However, for a proposed RRR project, existing poles were allowed to remain in place unless the crash data showed a crash history for a specific pole. In such a case, the existing pole was evaluated and moved to a safer location, and the possibility of burying the specific utility line underground was considered. If the evaluation indicated that a relocation was unnecessary, the requirements allowed the pole to remain, but if the highway was later reconstructed, all poles then were required to meet “new construction criteria.” This case example is anonymous to protect the identity of the STA and the UO in the state (e.g., to accommodate a situation such as a tort claim against the STA). Other Case Examples In addition to the previous STA case examples, Appendix E provides additional case examples of several STA practices regarding tree and utility pole safety, taken directly from an FHWA report (Jones 2016).

STA Case Examples 67 Moreover, the following resources are currently available for review online and detail many of the findings highlighted in this chapter: • Additional information on the WSDOT objective of eliminating utility object collisions: Washington Strategic Highway Safety Plan (Washington State DOT 2010) and online at http://targetzero.com/pdf/targetzeroplan.pdf • Guidance on placement of aboveground utilities within WSDOT highway rights-of-way: Chapter 9 on control zone guidelines in the state’s utilities manual (Washington State DOT 2019) and online at https://www.wsdot.wa.gov/publications/manuals/fulltext/M22-87/ Utilities.pdf • Additional information about the GDOT Utility Pole Safety Program: Chapter 8 of GDOT’s policy and standards (Georgia DOT 2018) and online at http://www.dot.ga.gov/Partner Smart/utilities/Documents/2016_UAM.pdf • Information on energy-absorbing pole installations: New Jersey breakaway poles and energy- absorbing poles (Gabler, Gabauer, and Riddell 2007, p. 8) and online at https://www.sbes. vt.edu/gabler/publications/Reports/FHWA-NJ-2007-018_Final-Report.pdf • Additional guidance on accommodating utility poles on highway rights-of-way: NCDOT Utility Policy Manual (North Carolina DOT 2014) and online at https://connect.ncdot.gov/ municipalities/Utilities/UtilitiesDocuments/Utilities%20Policy%20Manual.pdf • Information on incorporating utility pole safety into roadway design: NCDOT Roadway Design Manual (North Carolina DOT 2017) and online at https://connect.ncdot.gov/projects/ Roadway/Pages/Roadway-Design-Manual.aspx.