SAN JOSE – To ensure the safety of residents in the County’s most fire-prone areas, the Santa Clara County Board of Supervisors directed County Administration and County Counsel to identify actions to ensure the effectiveness of the California Public Utilities Commission (CPUC) order about the reliability of wireless service for County residents in Tier 2 and Tier 3 High Fire Threat Districts.
“In times of emergency and disaster, wireless networks are critical infrastructure for emergency response,” said Simitian, who made the proposal after attending an emergency services community event in the unincorporated Summit/Loma Prieta community in the Santa Cruz Mountains. “These networks are one of the primary ways emergency alerts and evacuation orders are disseminated, and that residents can access 911 and reach first responders.”
Since acting in July 2020, the CPUC has required wireless companies to develop comprehensive resiliency plans to ensure necessary planning and network investments are made to maintain service to customers during a disaster or power outage or shutdown. The rule includes 72-hour backup power requirements to ensure a minimum level of service and coverage in fire-prone areas, with wireless companies required to have this infrastructure ready for use within 12 months of the July 2020 adoption date.
The CPUC action further requested wireless companies to file comprehensive Communications Resiliency Plans detailing their ability to maintain a minimum level of service and coverage during a disaster or power outage.
Significant portions of Santa Clara County are designated as fire-prone, or Tier 2 and Tier 3 High Fire Threat Districts, including the Santa Cruz Mountains, from roughly Summit Rock in the north to just past Mount Madonna in the south including the Loma Prieta/Summit area, New Almaden, and portions of Los Altos Hills, Saratoga, Monte Sereno, Los Gatos, and the East Foothills.
Notwithstanding the PUC direction, Loma Prieta/Summit and New Almaden residents report regular cellular service outages, including from last year’s winter storms, and more regularly, PG&E outages. Based on these complaints, it appears that either the wireless carriers’ facilities may not be backed up in compliance with the CPUC mandate, and/or the wireless carriers are using the exclusions in the mandate to justify not having the 72-hour battery back up in place.
“Regardless,” said Simitian, “it doesn’t appear that the CPUC decision is accomplishing what it set out to do for residents in fire-prone locations. The reality appears to be that our County residents in these areas are as vulnerable as ever. The CPUC needs to ensure its mandate is being enforced, and that our County residents can rely on wireless service in times of disaster and power outages.”
The CPUC recently extended the compliance date for its mandate in an attempt to address ambiguity in some sections of the rule. For that reason, Simitian’s proposal directs County Administration and County Counsel to report to the Board with recommendations to formally engage in CPUC’s rulemaking process related specifically to maintaining service to wireless customers in fire-prone areas during a disaster or power outage.
In addition, the Board directed County Administration and County Counsel to report back with recommendations about potential engagement and partnership with Santa Cruz County; any potential improvements to County Planning Department and County Roads and Airports Department processes to ensure those processes aren’t hindering installation of backup power for wireless facilities: and/or necessary statutory changes.
“On the latter issue, my office has been working closely with Assemblymember Gail Pellerin’s office on these concerns,” said Simitian. “We encourage our County Administration to collaborate with Assemblymember Pellerin’s office should changes to current law be a consideration.”
In November 2022, Simitian co-authored, with then-Supervisor Mike Wasserman, a proposal to improve Loma Prieta community emergency preparedness and response planning. The following month, the Board approved the following actions, several of which were in partnership with Santa Cruz County (given that the Loma Prieta community straddles the boundary between the two counties):
1. Develop a memorandum of understanding (MOU) relating to shared responsibilities and support for sheltering operation and the activation of a local assistance center when needed.
2. Conduct community outreach event to provide emergency planning information and an overview of potential services during an emergency event. This event took place in August 2023 in conjunction with the Loma Prieta Community Foundation’s Annual Mountain Resident Night Out event. During the question-and-answer session, a consistent concern was voiced about the loss of cellular service to mountain communities when the power is out, not just in times of disaster such as the 2022-2023 winter storms, but also due to frequent PG&E power outages.
3. Conduct a two-county Emergency Operations Center (EOC) to EOC tabletop exercise which models different emergency or disaster scenarios and allows responders to review their roles and how they might react and coordinate their responses for such things as resource ordering, shelter support, local assistance, and recovery. This exercise took place in August 2023.
4. Hold a pre-fire season meeting of responding fire jurisdictions and law enforcement to discuss unified command, response, evacuations, evacuation routes, and mutual aid policies.
“Look, it’s a bureaucratic tangle. But the basics are pretty straightforward. In a time of emergency people need to be able to communicate to keep themselves safe. Right now, that’s not happening. And that has to be fixed,” said Simitian.