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Pepco defends tree‑wire installations and pole replacements, cites NESC inspections; double‑wood pole removals continue without single 'backlog' number
Summary
PEPCO witness Amber C. Young said the company’s tree‑wire installations and pole replacements were justified by engineering analysis and National Electric Safety Code requirements, and she said double‑wood pole removal is ongoing and cannot be reduced to a single snapshot backlog number.
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Amber Karina Young, PEPCO’s vice president of technical services, defended the company’s use of tree‑wire and the scope of pole replacement work during cross‑examination in PSC case No. 9655, saying engineers considered alternatives but determined those options were temporary solutions and that many pole replacements were required to meet National Electric Safety Code (NESC) standards.
On tree‑wire: Young disputed intervenors’ contention that Pepco failed to perform the correct cost comparison for tree‑wire solutions. "The correct and appropriate cost comparison is, it's a 64¢ difference between moving forward per foot difference between moving forward with ... bare wire versus tree wire," she said, and testified that engineers ran an analysis that justified the choice on reliability and system performance grounds. When OPC witnesses alleged Pepco had replaced 67 poles during tree‑wire installations that were not necessary, Young replied, "the 67 poles would have been required to be replaced regardless ... The reason the 67 poles were replaced is because of NESC standards," adding that pole condition and vertical spacing are standard engineering drivers.
Young also said Pepco considered alternatives raised by intervenors — cross arms, staggered insulators, spacers — but characterized those as temporary measures that would not address the underlying reliability needs identified during inspections and engineering scope work.
On double‑wood poles: The transcript and exhibits show a multi‑year effort to reduce legacy double‑wood poles. Young acknowledged Pepco removed 464 double wooden poles in 2023 at a cost she identified as roughly $1,500,000. She referenced company filings (annual reports to the commission) showing earlier removals of 1,950 (2018), 460 (2019), 781 (2020), and 1,095 (2021) double poles, which cumulatively total 4,386 removals across those years according to the company’s filings.
However, Young repeatedly told commissioners she did not have a single unified number in her testimony for the number of double‑wood poles remaining at the end of 2022 or 2023. "This number is gonna consistently change," she said, explaining that pole replacements are driven by inspections, failures or field conditions and that a pole cannot be removed until other attachers disconnect and migrate facilities. When asked for a definitive backlog figure for poles needing replacement within 1–5 years, she pointed to pole‑defect tables in company exhibits but said she did not have a measured backlog number.
Why it matters: Pole replacements and conductor choices such as tree‑wire versus bare conductor affect engineering costs, project scope and ultimately whether the PSC will allow cost recovery in a rate case. Intervenors challenged whether Pepco sufficiently considered lower‑cost alternatives and whether certain replacements were necessary; Pepco’s defense rests on engineering judgment, NESC compliance and inspection findings.
Limits: The transcript shows contested claims between Pepco and intervenors about alternatives and necessity. Pepco cited NESC requirements and inspection findings; intervenors questioned whether all capital‑intensive solutions were justified. The commission has not adjudicated those disputes in the excerpted record.

