tv Government Access Programming SFGTV October 13, 2019 9:00pm-10:01pm PDT
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seeing no questions. >> next item is capital financing plan. this is the fourth year we're presenting the plan to you. capital financing plan providing a snapshot of issuances you'll be asked to consider for approval during the upcoming fiscal year and provides a commission with visibility and transparency and the upcoming
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capital financing activities of the puc. this is important because the puc's large debt portfolio and credit needs and as always, our management activities both of an issuance and administration standpoint are guided by the various policies that you've approved in the past, including the capital debt service policies, which you approved in 2017, as well as debt and management policies and procedures and finally our debt and management activities are guided by our key debt stakeholders including the oversight committee. so on this slide, you'll see a senatsnapshot of the debt inclug revenue bonds, low-cost, state and federal loans and it shows the strong bond ratings each of the enterprise currently enjoys.
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the capital financing activities are centered around three areas. one, meeting the new credit needs to satisfy the ongoing capital requirements including determining when and how much funds are kne needed to be ang d and the debt portfolios which is one when replaced renewed credit facilities and finally, the continual monitoring of the markets to see if we can identify opportunities to benefit rate payers such as refunding outstanding debt for savings. so this slide is a bit of a busy slide showing the debt activities that we plan on bringing tow ove to you over the of the fiscal year, executing new low-cost loans, new money revenue notes and new money bonds for the water enterprise and as is always the case it
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seems each year of the approval of renews or credit facilities for our interim funding programs. later on today, you'll be asked as a part of your regular calendar, you'll be asked to consider one of these items. and the last item shown on this slight, which is not a dead issuance is the bond authorizations for each enterprise. what's not shown is a financing that we plan to bring to you in a month, november 26th, meeting. and interest rates are low right now and we've identified working with advisers, identified a refunding transaction recently. it was too late to get it into the capital financing plan but i wanted to report to do a water revenue. hopefully the market continues and once you consider this transaction on the 26th, we can enter the market right away
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and execute what we think would be a favorable transaction for the water enterprise. >> excuse me. can you explain that again. so that would mean a new refinancing mechanism, basically. >> we're taking outstanding water revenue bonds and because interest rates are slower right now, we are going to issue what's called refunding bonds to refund the outstanding debt so you're replacing debt at an interest rate with new debt at a lower interest rate representing u.s.a.ingssavings rates to the . payers. >> it's the same concept of the mortgage, except for dollars.
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>> slides, please, donna. good afternoon, commissioners, acting director of the water programs. a couple of things today. first i'll start out with the update for the quarter ending june and i think the next item is the waste water enterprise quarterly report and i'll go over a question commissioner maxwell had at the repairs. so dropping into the program status, phase one are currently 32.2% complete with $833 million expended at the close of june. this quarter we were able to progress five projects out from
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the preconstruction phase phasee planning design. we have 13 projects in construction in green and we're able to progress six more projects into the close-out and completed phases which are the grays in the pie. i'll go over the hue light hue . solids will initiate the phase. during the quarter, the design team finalizes the outpackages for sur relocation, demolition excavation and foundation work. the team is also working to bring on the power, waters and sewer didn't telephone utilities and the starchin staging area fm and as the commission requested, we plan to provide a major update of this project on the
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october 22nd meeting. moving on to the hedgework's project, the team is progressing with two of the five scopes. for scope one, the contractors are working hard to complete the building demolition and finish the bypass pipe work and the other dry-weather dependent work on scope 2a exis the pumpwhich p station. scope 2b, the team has completed 100% zion for this quarter for the influence, sewer and force main. for scope 2c, the southeast list station and the team is is working toward the design early next quarter and on the main headwork's project, the first of
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the suggestion waves of construction work packages are currently processed for ntp. we plan to provide a more-day-old project update at our october 22nd meeting. and move on to other projects. this sunset green boulevard, phase two will reduce sewer discharges around sunset boulevard. phase one was a pilot project for two and a half blocks, constructed by public works. phase twphase two will be 12 blm luola to you'r irving within the existing green space and incorporates a curbside inlet from the street, pipes it into the rain garden and allows it to soak into the landscape before it enters our combined sewer.
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we received two bids in june and we recently issued ntp to the low bidder in late september. the north shore push station is 35 years old and due for a major upgrade with four existing dry-weather lift pumps and allows for them to operate as redundant wet-weather pumping, providing wet weather conditions. this project will include improvements to the bar screen, as well as an overhaul to other systems, including the electrical, push controls and distributed control systems. and this project was advertised and was slated to start construction in september, but, unfortunately, due to overall safety program concerns, we have
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elected to close the bidding and we will bring forward a prequalification process to validate bidders before soliciting for actual bids. >> i was going to clarify why we are pausing these projects, because we're working with the city attorney's office to put qualifications or prequalifications for contractors to have a good safety record and because we've been having contractors and we had some projects and we wanted to make sure whoever comes in on these projects have a good safety program. >> you must have read my mind but i wanted to ask a question, the new pumps that you're putting in. , how are they different from the old pumps?
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>> well, they're fairly the same. they have to meet the same pumping curve and for dry weather but if you go back to the slide, sorry -- so we're basically rerouteing the flows from the dry weather pumps through a manifold system back to the wet-weather said to do both when w. when we replace dry-weather we're replacing that pushing bud adding redundancy, as well. >> just wanted -- you have to be careful because they went on the equipment so they know all about pushes. pumps. >> vertical, nonclog. >> you won't be surprised at what good students we were. [ laughter ] >> this timeline shows how some
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of the other major phase one projects are progressing. the red line shows us where we are as of june, blue line through design and environmental phases and green represents construction grades close-out and just a quick note is that we plan to start construction on the southeast plant seismic rehab project in the fall. continuing on, the division strategy project, the ntp was issued and the team is performing concrete repair, as well as implementing or repairs to the back-flow controls at the csd structures. a lot of this is nightwork. but our construction completion is anticipated to be completed
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around the summer of next year. the balker beach green street infrastructure project is in construction and this is the one we had a grant for, roughly, i think 3.7 million from the state. and we have recently encountered un-foreseen site conditions including a turn-of-the-century duck bank and human burials. the team is working with the planning department to quantify the remains and working with the team to return the remains to coma. lastly, the oceanside digester gas utilization is in construction with an anticipated completion by february of 2021. work is progressing and this is a project that requires much coordination with the other adjacent ongoing project at that plant.
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lastly, a bit about our other work, we completed our six-month update to our jobs and contract's report. that highlights our efforts and successes providing opportunities for local residents and contractors to participate in our work. in may we hosted the 13th ants 13th annual contractor's breakfast which has been a big event for us and our contractors, for local businesses, to hear about what we're working on and what our upcoming opportunities are. these are examples of how we are leveraging our infrastructure assets or investments to support the local community and our local economy. we're proud of this work and we look forward to continue to expand these efforts. and with that -- >> i just wanted to point out, anand this is for francesca. i went back to rec and park
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conscience. >> yosemite creek, they are interested in teaming up with us but artificial turf because they're concerned of the gopher holes they have in the park and they female that they identify artificial turf, which is more tornadmore -- i guess they movey from the rubber. >> there's a call for an update and that you let me know and i
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appreciate you bringing that back to life. i think it's an important highlight to explore and see if we can then replicate. i don't love artificial turf and it seems to somewhat defeat the purpose of green infrastructure. >> how does that help our sewer system? >> that's a big fight at rec and park of having natural turf versus artificial turf. having sons that play soccer and baseball, you step in the gopher holes and that's why it's been something of contingency in rec and park. >> of course, i was going to say the same thing and i recognise the gophers and the gopher holes. there must be some way to do it because i can't do anything in
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my backyard because these gophers are rough but i think there has to be something rather naturally and creative that we can do because it does seem rather to defeat the purpose, but i think there are two different goals and that's what we have to reconcile. >> whack-a-mole. [ laughter ] >> i think wea we're setting upe meeting. >> any other comments or questions? to the general public, comments, questions? oh, i have a question, actually. >> you are going to get to th the -- i have a question on greenways, very specifically like the sunset you reported on.
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why do they cost so much money and what am i missing? >> i mate hav might have to geto you on that. it took awhile tor u for us to k the pilot. that was one of the first ones we did and we worked with the public works to try to construct that and it took some time and probably still trying to finalize what that cost was. we know better now. the bids came in well. we had a good contractor and we're anxious and happy to move forward on that project. >> i appreciate that. >> referring to the irving thing, the 8 million. >> it was 8.4. it just seems -- >> i just wanted to make sure. >> it seems so simple and i must be missing something that is involved with it. >> we could come back and report on that, to have you do that.
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than >> thank you. now if you could answer, commissioner, the next question. >> i was hoping to go through the waste water. >> i called the waste water first so you can answer it and wenandyou went ssip. >> sarah, could you maybe speak to the cost because i have a better understanding because we've talked a lot about these projects. >> there's a couple of things with the pilot block. we encountered problems with the steep learning curve and no staff that new about green infrastructure. the public work's staff tasked with implementing the project needed to be trained from beginning to end on how to do it and ended up that the unit costs were higher than our engineer's estimate and since that was a
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learning block, we then said, ok, let's document or lessons learned and try putting the next piece out to bid and so we had help from harlen, saying o, we'lok,we'll try it this way ane how the different ways can reduce our unit costs. what we're finding is that teaming up with public works for design can be fine but for construction, putting it out to bid is more cost effective. so with this bid that we're getting for the second phase of sunset, they're much more align wialigned with the engineer's estimate. it seems like it should be easier to implement or less costly. the reason it does cost that much is that we're not just managing rain that's falling on the project. we have to capture what's called
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the drainage management area which so that infrastructure is draining stormwater from impervious services around the rain gardens. so the design, the grrating, the soils and plants are sooned ando capture unleinlet areas. it's engineered structured that requires site-specific building interventions during construction and that is what generates the unit costs that you see for storm water management. >> sunset boulevard has been our highest area, because we have
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infilinfiltration over 40-inchen hour. with infiltrated 90% of al it during the rainy season. >> i'll have to learn more. it seems like a lot of money. >> we could do a presentation for you in more detail, if that would be helpful. >> our next one that we do, that would be good. >> ok, i'll note that, thanks. >> so we finished the sewer system improvement program update, and did we do a pub pubc comment. >> i believe so. >> you want to do the waste water one and start by
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responding to sophie's question. >> sure. you're correct, when we first initiated the emergency declaration, we really didn't quite understand or know the actual costs. i think we were projecting it to be 2 million or 3 million, i believe, originally. we brought on a contractor, power engineering, a marine contractor and came in and looked at the project and the designs and they quantified that there's no way to build it for that amount of money. so we did change the first to a $5 million amount. starting into construction, we had to change some of the construction methods, as well. we had to bring in a barge and actually build a barge at that location because we had to cross two bridges. the bridges weren't working is we had to build a barge and walk
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our crane on to that barge and that required money. we had to change the shoring system to a coffer dam system. we had to change the shoring method and add a monitoring system, a vibration monitoring system for the palms t paper. pipes. of course, soils themselves are hazardous and we had to dispose of those in a legal way and those are the extra costs that we are looking at now. the good part is, actually, that our pipe is actually constructed
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and conducted, and so that leak -- that temporary pipe is fully connected and we're looking to activate that in the effect couple onext couple of d. >> my concern is that it says that more poor soul conditions, limited waterside access, active marine life and delapidated and larger than expected void underneath the pipeline alignment. so i guess my concern is, what is it that you're putting this -- why should we think it will be better and, you know, when all conditions exyoand you having to shore it up, i'm concerned of the lifetime and what can happen because of the sentimentsediments, we don't kns
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in it. >> it's a temporary piping system. we have a permanent project which will reroute around, further away and around this access area. >> sorry for the long story. sounded like a typical day. [ laughter ] >> you can go ahead. i have to get the approval. >> ask for the slides because sfgtv. >> there are no slides for this one. >> i'm howard fung and for this,
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the waste water bee enterprise. our forecasting extensions by six months or more or have cost variances for 10% above the approved budgets. the first one is the southeast plant, power feed and primary switch gear project. this is behind schedule because we need to rebid this project. bids were due and received in may, but we had to reject the bids. and as harlin mentioned, we're going do a prequalification process for this process, as well, so there's a lul little ln that time. the central bayside system, phase one, is behind the schedule. phase one is to complete the
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design for the 35% level and we are currently extending out and we're looking to reprioritize the remainder of the project and there's a little delay there. the permitted project, which is the southeast bay, the crossing replacement project, that's a long one. this is behind schedule, around eight months. we needed additional tame to incorporattime toincorporate thr the emergency contract and we anywayed to complete, of course, the sequa review. the rehab project, this one is projecting above the baseline budget due to higher costs from actual bids received. we did have to rebid, as well welcome and completion is slated for next year and that completes
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my report. happy to answer my questions. well >> a question i have has been answered, but i'm concerned when i look through the report and see the red dots. for example, on page 9, and also the time it takes to get up to speed on the project. and what can we do in the future so this isn't happening. overall, i could see that we've never seen a report like this with so many red warning saints. signs. some of these projects, a lot of interdepartmental projects, sometimes their schedules are out of our control. we deal with mta and public works and depending how their
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schedule is, we have to coordinate because we only want to dig the roads once. we partner and caugh coordinatee projects with those agencies and it takes awhile and we get dragged along. some of the other projects, we're gettin getting higher bidd our prices rest that and some of the budget projects are higher. but overall, we're trying to look at that to recoupe savings as we can. >> that makes sense, thank you. put. >> i would just say that overall and this is -- we're actually getting some data, not only in the bay area but nation-wide, prices, construction prices are going through the roof with the tariffs and with the labor and we're reaching out to atlanta, chicago and other cities
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experiencing similar situations with the other costs to see what strategies to do as an industry. it's challenging because you have to do these projects. we were fortunate enough before the water system improvement program, before the olympics in china, where prices went through the roof. and our program was trending a couple billion dollars over the program, but then, all of a sudden, you know, the economy just tanked and we're the only game in town and getting bids 40% lower than the engineering estimates and everybody was a hero. so i'm hoping that this happens again.
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little to come up and present. >> thank you. this item will be our first time in public talking about the information, about the city's nonbinding offer to purchase electric facilities from pg & e. the offer was made on september 6th and it cover -- it was covered extensively in the news on september 8th. the commission has, of course, been engaged throughout the development process in closed session. this will be our first public presentment and there will be another session today for further q & a and guidance from the council. slides, please. so the nonbinding offer was made after extensive staff and consultant work. that work was conducted at the request of mayor breed and the board of supervisors and under
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the guidance of counsel, the city attorney. this work was published in moose jaw. may. this is available online, on our website, sfwater.org. if folks want to take a look, click power, about us and than n the link. let's make sure everybody has the basics first. sanfrancisco is a department -- sorry, sfpuc is a department of the city and county of san francisco. we operate a water utility waste and stormwater utility and it operates two retail electric
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service. it's hechhe power is a public utility serves city functions and new developments. city functions are like the muni system, the general hospital, the airport, fire and police stations, public schools. some examples are the shipyard, mission rock, treasure island and clean power sf is a community choice program that serves electric supply only to businesses and residents here in san francisco. together, these two programs were serving 80 also of the electricity consumed in san francisco. and that makes san francisco the primary supplier of electricity in san francisco. pg & e provides the grid services, and that's depicted
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hear. here. the city has paid for both programs and that's $300 million a year if distribution fees by and over time, san francisco has been reducing the energy dependency but in that grid, that reliance, we do encounter difficulties. these difficulties increase the cost luk like seen yes senior ae housing and there's safety and financial challenges. they have an alarming set of safety violations. they failed for bankruptcy protection and today's big news, they're attempting to manage wildfire liability with planned
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power shut-offs in 30 counties and northern and central california will be affected. mayor breed requested a report to explore the options and that report, which i said was issued in may, identified three options that are listed here. and full independence depickettedepictedon the right,f public funds, oversight accountability, achievement of san francisco's climate action goals i and that was identifieds the best option for san francisco. so further exploration on acquiring pg & e lor assets continued. this put the cost at a few
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billion dollars and the focus became answering this big question. this big question governed our study paths and informed nonbinding offer submitted to pg & e and let's break this down. can san francisco purchase the assets? we're talking about electric transmission and distribution assets that serve san francisco, the inventory and control, streetlights, everybody it takes to operate the system. invest and separation costs. that's the separation costs between that we will incur to modify pg & e to create boundaries that they would continue to own and san francisco would be the owner of between our systems and pg & es allan the southern border and
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provide reliable, safe public service. that's the cost to achieve the goals. these goals are included in operating, maintenance, administrative expenses and capital expenses. when we say consistent with our values on clean power content, we're talking about the same supply costs incurring as an organization for our clean power sf program. since we're searching a portion of the city, it's really only looking here at that increment we're not serving, so about 20%, that last 20%. and equity. wear proposing here to spend the same amount of dollars that pg &es & e collects as an operag cost. while meeting financial requirements, it means this program and the way we look at acquisition of pg & e assets and operating a full scale utility
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throughout san francisco, it would need to meet the same financial requirements that we currently operate under and that our waste water operates under. and then this chart illustrates that. we know we wouldn't go forward if we expected it would cost san francisco more electric service. so we set a revenue ceiling by this black line, base on the other hand a projection of pg & e rates over time and you can see this illustration goes out to year 2050. we calculated the operating costs and funded capital improvements for reliable, sustainable service and equity goals represented by the yellow line, the accumulation of cost to operate the utility, the electric utility serving all of
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san francisco. we factored in the cost of the purchase price and that's represented by this blue triangle and the net revenues, the greenish triangle shows that all costs come in below the revenue so the acquisition is fundamentally sound. and we anticipate future rate savings for san francisco at a $2.5 billion offer price. that price was informed but our due diligence study efforts. and we utilized publically available information through the federal energy regulatory commission, securities and exchange and that pg & e makes and relied on multiple experts noted here with jeffrey's llc taking a lead role. jeffreys is the largest u.s.
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located independent bank. together with these experts, we arrived at the nonbinding offer and they're is the summary of that offer. the offer is the significant cash infusion to pg & e at $2.5 billion and that's a cash that the rate payers would not have to pay back. it would facilitate a timely emergence from bankruptcy with a premium valuation included there due to the unique expedited circumstances we'd be in given the bankruptcy time frame. and it's an offer for targeted assets that are identified here. more specifically, the 230 230-150 kv transformers, street lights, warehouse service yards,
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systems, rolling stock, inven is in hope with pg & e. also on documentation and ancillary agreements, such as an approval from you, the sfpuc and board of supervisors and outside approvals from the bankruptcy and regulatory agencies. as we said in our preliminary option's report in may, we also lacked furthelooked further at l fund. so first up, the pg & e, our analysis shows modest impacts on other pg & e rate payers that is
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fair to all customers. san francisco's leaving, we estimate, would increase other customer's bills less than a dollar a month, much less than a dollar a month. the pending request, that's the california puc, would increase bills by $30 a month. the premium value that we're offering in that 2.$5 billion offer includes a gain on sale, some of which can be used to make remaining pg & e customers whole. san francisco is not pursuing this offer to avoid wildfire costs. the city will pay for and use the transmission services. sanfrancisco will pay for operation and maintenance costs on the transmission system and vegetations management and all things we're paying for, we would pay for even were we to be
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become the provider of electric services for all of san francisco. that's the impact on others. so now let's take a look at what the impact is on san francisco's general fund. the acquisition would be funded by revenue from electricity sales. these are funds that are only available if we actually go forward with the acquisition. wear not drawing funds away from other city priorities. there has been a campaign by ibew, local 1245 that makes that assessoassertion and that's a m. the city would be compensated for revenue loss from the reduction in pg & e's business in san francisco as would be appropriate. again, that won't be funded from revenue, electricity sales. i'm talking about property taxes, gross tax receipts, fees, that sort of thing and we wouldn't be leaning on the city's credit rating at all or use the city's credit capacity.
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we would be relying on a post acquisition power enterprise credit using the authority the granted us a year ago june. and then i think the last impact we've been hearing folks ask us about is on the pg & e workforce. as you folks all know, the city employees a union workforce and we have a long history of working productively with the unionized workforce. they will recruit willing employees who maintain the electric facilities. we value their knowledge, skills and abilities. san francisco offers stable careers with appealing wages and benefits and we seek in the offer letter, the cooperation of pg & e to recruit appropriate personnel. we would want to negotiate a transition plan with pg & e for a smooth hand-off that protects safe and reliable service.
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having said all of that, we know that this is a major complex undertaking that has risks. let's take a moment to talk about the risks and what our mitigations are. that's what you see on the slide. one of the risks is the asset condition. we've made some assumptions based on what is publicly available about these assets. so there's a risk that we're wrong on that. the mitigatio mitigation is sube diligence and publication review. it will be in the system, required regardless of whether the city is the owner or pg & e is the owner. it's just now the city under this scenario would be responsible for making the decisions about updates. improv. everything wav we've talked abos based on projections.
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it's been independently verified and we're going through an ongoing refresh and review as we learn more. staffing up is a risk and challenge. we would be hoping to employ from pg & es existing employee base and then we would rely on contractors to fill the gaps while hiring efforts would opportunity. pace is a risk. the bankruptcy proceeding is moving pretty quickly and they have a looming deadline associated with the pg & e to have a confirmed plan. we have an experienced, knowledgeablknowledgeable team s through that on the earlier slide with transaction counsel. financing and credit, this is a risk but as you heard from the debt manager, we're quite familiar with the municipal market and doing a lot of debt management today and that would
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continue under this new structure. and then, of course, there are benefits not quantified. and that's what you see listed here. this is the hope for a prospect of what we get after going through the effort to make the acquisition. with woulwe would have system c, control of the grid and that would help us to support our project and program objectionives toward decarbonization, actually energization of city projects and businesses, business and residential projects, undergrounding, local generation, storage, energy efficiency and we would have rate-making control supporting city values, like modifying the eligibility reimbursementeligibe would be removing the opt-out
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risk through the business model and all of the regulatory risks that go with that business model. so that was a conduc quick run n the offer that we made to pg & e and with that, i'll take question. >> i have a couple of questions through the chair. one is, and the one that would be the most important, to my heart, would be that if this transition took place, the people currently members of 1245 and local 20 that were for pg &est would not receiv & e wo. the transition and tons of people say, i don't care. if there is a gap, the listing of contractors to fill the gap,
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this is always a red flag for me because contractors, you know, are definitely wanting -- i assume they would be regular contractors. so making sure -- i'm talking about paychecks right now on this point. secondly, you know, there's a lot of federal laws, you know, involved in pension plans and whatever, defined pension plans if they're working for pg & e or the pte local 20 folks and i know that there are certain things that have happened, including with the housing authority that is going through its transition and shutting down that the city has a history of maybe buying out credits from the plans that people do have and the vesting they have in the current pension plans and therefore, if they did come into
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the city plan, they wouldn't come in at step one and start accruing hours, but they would say if they worked for pg & e for five years and wanted to come to the city, that the city would be involved in using that as an expense to make sure people wouldn't lose their requirement. so those are two markers i want to put down and i don't know if you want to comment on that. the second thing, which is a much smaller one, earlier in your program. you wondered if you could explain this. there was a piec piece when you talked about -- you don't require if the word was obstructions or problems. all of it, you know, gets into the san francisco system, the new wonderful system that you
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guys have been implementing over the last years. but when it comes to a comment that said some of the city's priorities, like affordable affe housing are obstructed by pg & e and i wonder if you can elaborate and why there's an obstruction to affordable housing, pg & e and the relationship with the areas that have that would obstruct that. >> happy to, talking up first your comments with the workforce issues. the general manager and the mayor already sat down with representatives of local 20 and 1245 to express our sincere interest in having a pathway of employment and to be able to take advantage of the knowledge, skills and abilities of that workforce. the folks most familiar are the
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pg &es & e workers and we woulde an opportunity for the employees to join our workforce if we are successful in this acquisition. with respect to the question about obstruction -- >> i know that meeting happened. you didn't say anything about details, about wages or pension, which is what i was asking about. you know that didn't get discussed in total depth, other than the city taking that policy. >> so as barbara stated, we had the meeting and i think both unions were pleased that the mayor reached out to rag out toe we put a proposal out there.
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i think both unions felt they would opportunity to support pg & e, keeping their assets. however, if they feel that the situation would change, that they would be willing to work with us on that, but they felt that the time is not ripe right now to sit down and talk to us. we've received a letter, i think, from ibw, pretty much saying that. but meanwhile, we're looking at pensions and stuff and seeing what the difference is and seeing how we can address that. to make it enticing from folks from the pg & e to come and work for the city. >> and we know -- sorry. >> there kelly, i know that we
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have -- there's a glee about maybe going to the raw raws race bottom with rates but a race to the bottom changing the job compensation is a huge concern. and i'm glad you're studying it, but it's important that that stays furthermorel firmly on the saying this is what we want to do. out we can't have collateral damage in a city like this, where you put in old letters. this is a union town. >> route. right. the second issue of unaffordable housing and how and the city's efforts are being hung up, if you will, by pg & e. when we interconnect to the grid, it's their grid. there's a wholesale distribution
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tariff with service that pg & e has at the regulatory commission. it lays out those terms that we're supposed to be able to use to get fair access to pg & e's grid. we don't object to the rates at all that were charged for wholesale service by pg & e but the terms associated with connecting to the grid have been challenging for us. it's been very inconsistent with what we understand to be good utility practise.
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