AB-112 Implementation of All Electric New Construction Regulations

 

NO. AB-112   :
DATE   :	Effective June 1, 2021
SUBJECT   :	Administration and General Design
TITLE   :	Implementation of All Electric New Construction Regulations
PURPOSE   :	The purpose of this Administrative Bulletin is to detail standards and procedures for the implementation of the all-electric new construction requirements of the San Francisco Building Code effective June 1, 2021.
REFERENCE   :	2019 San Francisco Building Code; 2019 San Francisco Green Building Code; San Francisco Administrative Bulletin 005: Procedures for Approval of Local Equivalencies; 2019 California Building Standards Code; San Francisco Environment Code, Chapter 7.

 

CONTENTS

1)   Discussion

2)   Criteria for Exception Allowing a Mixed-Fuel Building System or Area

3)   Review for Determination of Infeasibility

   a)   Reviewer Qualifications

   b)   Reviewer Submittals

4)   Submittals Requesting Exception Allowing a Mixed-Fuel Building System or Area

Attachment 1:   Design Guideline for Electric Ready Buildings

Attachment 2:   Final Compliance Verification

Attachment 3:   Application for Exception for Commercial Food Service

Attachment 4:   Application for Review of Pre-Existing Agreement

Attachment 5:   Summary of Investor-Owned Utility Options for Proposed Electric Load Exceeding Capacity of Utility Infrastructure

1)   DISCUSSION

Approved construction documents and completed projects must conform to requirements established in the San Francisco Building Code. San Francisco Building Code 106A.1.17.1 requires applications for permits submitted after June 1, 2021 to construct new buildings to be designed and constructed such that all space conditioning, water heating, cooking, and clothes drying systems are all-electric, as defined, and prohibits installation of infrastructure, piping systems, or piping for distribution of natural gas or propane to such uses.

APPLICABILITY

San Francisco Building Code Section 106A.1.17.1 applies to all permit applications submitted on or after June 1, 2021 proposing to construct one or more new buildings in San Francisco.

In the case of Site Permits, the effective date is the date the Site Permit application (not an addendum) is filed with the Department of Building Inspection. Addenda to site permits and revisions to permit applications received before June 1, 2021 are not required to meet the requirements of San Francisco Building Code Section 106A.1.17.1, unless the addenda or revisions change the scope of the project such that current codes are generally applicable, or such that an exception granted on the basis of infeasibility is no longer warranted.

Areas Specifically Designated for Commercial Food Service

For projects which submit an initial application for permit:

   •   On or after June 1, 2021 and before January 1, 2022: Areas specifically designated for commercial food service may provide gas piping systems, fixtures, and infrastructure exclusively for cooking equipment within the area designated for commercial food service.

   •   January 1, 2022 or thereafter: Permission may be granted to install gas piping systems, fixtures, and infrastructure exclusively to serve cooking equipment within an area designated for a specific commercial food service establishment, such as a specific restaurant. To provide sufficient evidence that gas infrastructure and piping are necessary, the following must be provided by completing Attachment 3: Application for Exception for Commercial Food Service:

      °   Name of the food service establishment and food service establishment owner contact information

      °   Specification of the gas cooking appliances proposed, and fuel consumption rating for each device

      °   For each proposed gas cooking appliance, state the reason gas is necessary, such as technological availability or specialized food preparation process.

Projects that contain gas piping systems, fixtures, or infrastructure serving cooking appliances are by definition “mixed-fuel” and subject to applicable requirements (see Administrative Bulletin 93).

DEMONSTRATION OF COMPLIANCE

San Francisco Building Code Section 106A.1.17.1 is a provision enacted for protection of health and safety. For administrative efficiency, no special documentation is necessary for projects that comply with San Francisco Building Code Section 106A.1.17.1. Projects that do not seek an exception are to document compliance via normal documentation requirements and procedures, such as:

Piping Systems and Mechanical Systems

Project submittals providing any construction detail related to piping systems or mechanical system design must be all-electric and consistent with the requirements of San Francisco Building Code Section 106A.1.17.1. Documentation of compliance with California Title 24 Part 6 Energy Standards shall not include any indication of gas consumption for space conditioning, water heating, cooking, or clothes drying.

San Francisco Green Building Standards

Administrative Bulletin 93 (Implementation of Green Building Regulations) provides guidance for understanding which provisions of relevant local ordinances and state building codes apply to a project, describes implementation procedures, and provides forms to document compliance. Compliance with San Francisco Building Code Section 106A.1.17.1 (or Environment Code Section 706(d)(7) in the case of municipal buildings), shall be documented as required by Administrative Bulletin 93:

   •   Permit applications for new construction are not accepted without Green Building Site Permit Submittal GS-1.

   •   The submittal package for each addendum that includes architectural details must include a Green Building Submittal checklist incorporated into the project plans indicating the required measures and referencing location of such features in the construction documents and providing compliance details for each requirement. For newly constructed buildings, either GS-2, GS-3, or GS-6 is required with each addendum.

USES NOT SPECIFICALLY REGULATED

An All-Electric Building or Project as defined by San Francisco Building Code Section 202 relies on electricity as the source of energy for all space heating, space cooling, water heating, cooking, and clothes drying. In addition, building permits are prohibited for projects proposing gas piping systems, fixtures, or infrastructure for decorative uses and lighting or onsite generation of electricity (except where primarily fueled by onsite digestion of organic material). Gas piping systems, fixtures, or infrastructure may be installed strictly to serve areas and systems outside the scope of the definitions of an All-Electric Building or Project, and a Mixed-Fuel Building, such as industrial processes.

In projects that include uses not specifically addressed by San Francisco Building Code Section 106A.1.17.1, all space heating, space cooling, water heating, cooking, and clothes drying systems must be designed and constructed as all-electric, and such a project is defined as “all-electric” for the purpose of compliance with San Francisco Green Building Code 4.201.1 and 5.201.1.2.

EXCEPTIONS

Compliance with San Francisco Building Code Section 106A.1.17.1 and all other requirements for new construction have been determined to be practical and feasible. An exception may be made only when either:

   •   An all-electric project is demonstrated to be physically or technically infeasible, OR

   •   Where application of San Francisco Building Code Section 106A.1.17.1 would violate the terms of an existing development agreement or other contract with the City.

This bulletin describes the process for determination of infeasibility and grant of an exception allowing installation of natural gas piping systems, fixtures, or infrastructure. An exception shall only apply to the extent necessary to resolve the demonstrated infeasibility, or to the extent required under the development agreement or other contract.

Some development agreement projects or other multiphase projects may entail separate applications for permits to construct infrastructure serving an area versus buildings constructed after infrastructure is developed. San Francisco Building Code Section 106A.1.17.1 applies to any application to construct a building submitted to the Department of Building Inspection on or after June 1, 2021. If a project sponsor believes that application of San Francisco Building Code Section 106A.1.17.1 to a phase of development or to an individual building would violate the terms of a development or other agreement with the City, the project sponsor may seek a determination using Attachment 4: Application for Review of an Existing Agreement. Department of Building Inspection staff will refer the matter to the City Attorney’s Office to analyze the request for exception and the extent to which all or part of San Francisco Building Code Section 106A.1.17.1 will apply.

2)   CRITERIA FOR EXCEPTION ALLOWING A MIXED-FUEL SYSTEM OR AREA

San Francisco Building Code Section 106A.1.17.1 allows for approval of exception allowing gas infrastructure and piping systems to be installed on a case-by-case basis where All-Electric construction is demonstrated to be physically or technically infeasible. Physical or technical infeasibility is understood to refer to an exceptional situation where:

   •   A project proposal cannot be accomplished due to physical or technical constraints specific to site and occupancy that prohibit elements, spaces or features necessary for full and strict compliance with all requirements for new construction;

   AND

   •   If a specific system or area is served by gas piping systems, fixtures, and infrastructure, then the physical or technical infeasibility is resolved, and the project is able to attain full and strict compliance with all requirements for new construction.

To qualify for such an exception, the project must:

   1.   Undergo a Review of All-Electric Feasibility, resulting in a determination by the reviewers that there is no means by which a proposed function or service may be provided by an all-electric design compliant with all applicable codes; and that the proposed function or service can feasibly be provided if gas piping systems, fixtures, and infrastructure are installed.

   2.   Limit installation of natural gas piping systems, fixtures, and infrastructure to the system or area for which All-Electric design is infeasible;

   3.   Ensure the area and system served by natural gas piping systems provides for future conversion to All-Electric, by complying with the applicable provisions of Electric Ready Design Guidelines (Attachment 1) to the maximum extent feasible.

   4.   Demonstrate that the project’s modified design provides equivalent fire-protection and health and safety to All-Electric design.

Financial considerations are not a basis for determination of physical or technical infeasibility.

Criteria for determination of infeasibility:

 

Category	Criteria
A) Energy Standards	Compliance with Title 24 Part 6 Energy Standards for all-electric design may be infeasible only if there is no prescriptive option for compliance with the Energy Standards, nor an option for compliance under the performance method for any system or technology serving the specific use. Proposal to install a technology, system, or design not allowed under the Energy Standards does not demonstrate infeasibility where all-electric technologies, systems, or designs are available for compliance with the Energy Standards.
B) Electric Utility Infrastructure	All-electric design may be infeasible if: •   Electric load calculations are prepared for both mixed-fuel design for a specific system or area, and all-electric design, with equivalent occupancies, functions, and floor area; and •   The project submits an application for service to the electric utility serving the project; and •   The utility determines that (a) the peak electric demand required for the all-electric design option cannot be served, and (b) the peak electric demand requested for the mixed-fuel design option can be served under substantially similar conditions. Substantially similar conditions shall include equivalent occupancies, functions, and floor area, as well as the same consideration of the time required for the utility to complete modifications to utility infrastructure, where necessary. •   Where electric service is being provided to a customer by the San Francisco Public Utilities Commission (“SFPUC”), and SFPUC confirms the peak electric demand requested for the all-electric design option would directly or indirectly require SFPUC to do any of the following:    (i)   Revise a previously submitted application for service to Pacific Gas and Electric Company (“PG&E”) that is still being reviewed by PG&E;    (ii)   Submit a new application for service to PG&E for a load for which there is an existing service agreement with PG&E;    (iii)   Alter plans for electric infrastructure that have been approved or alter infrastructure that are under construction; or    (iv)   Make changes to existing infrastructure that would impair or limit a contract right that exists as of the effective date of this ordinance.
	Situations (i) to (iv) above do not represent a basis for a finding of infeasibility if the same issue applies to a mixed-fuel design constructed at the same site with equivalent occupancies, functions, and floor area. Situations (i) to (iv) will only apply to developments where an application for wholesale electric service relating to the parcel has been submitted to and deemed complete by PG&E as of the effective date of the ordinance, and the project sponsor demonstrates it is physically or technically infeasible to build all-electric within the electrical capacity constraints documented in existing applications for service to PG&E for the purpose of serving buildings that were planned but not yet permitted as of the effective date of the ordinance. An over-estimation of ampacity requirements for all-electric design compared to mixed fuel is not a basis for exception. Under California Public Utilities Commission Rule 2.C, utilities are obligated to provide service. Request by the utility for the customer’s proposal to comply with applicable tariff, easement, safety, and reliability requirements, or for reasonable time to construct improvements, is not a basis for infeasibility.
C) Physical Constraint in Small Infill Sites	All-electric design may be infeasible if: •   Electric load calculations are prepared for both a design including a specific mixed-fuel system and area, and all-electric design, with equivalent occupancies, functions, and floor area; and •   Based on the rules published by the electric utility serving the site:    °   Peak electric demand for the mixed-fuel design does not require the installation of an electric service transformer; and    °   Peak electric demand for all-electric design with the same features requires the installation of an electric transformer; and •   The site has a linear footage of street frontage of 75 feet or less;1 and •   Joint review by the Planning Department and Public Works Department determines there is no feasible option to locate an electrical transformer in the building or elsewhere on the property, and:    °   The only feasible option is to locate the transformer in a sub-surface vault in the public Right of Way; or    °   The sidewalk at the site is less than 10 feet in width, such that a sub-surface vault in the public Right of Way infeasible.
D) Exceptional Circumstance	All-electric design may be infeasible if •   It is demonstrated physical or technical constraints specific to site and occupancy prohibit elements, spaces or features necessary for full and strict compliance with all requirements for new construction; and •   If gas piping systems and fixtures are substituted for electrical equipment serving a specific system or area, the project is able to attain full and strict compliance with all requirements for new construction. Proposal to install a technology, system, or design that is inconsistent with, or not allowed by the discretionary determination by a City agency shall not be a basis for demonstration of infeasibility.

 

3)   REVIEW FOR DETERMINATION OF INFEASIBILITY

Compliance with San Francisco Building Code Section 106A.1.17.1 and all other requirements for new construction have been determined to be practical and feasible in general. San Francisco Building Code Section 106A.1.17.1 allows for approval of exception allowing gas infrastructure and piping systems to be installed on a case-by-case basis where All-Electric construction is demonstrated to be infeasible.

The conditions of infeasibility depend substantially on design details, and design development provides substantial opportunity to address physical and technical conditions. An application for design review for exception due to infeasibility will not be approved in the absence of substantial architectural detail, including the architectural addendum and Title 24 compliance documentation.

Prior to DBI review of an application for exception due to infeasibility, a Review of All-Electric Feasibility must be completed by engineers with specialized understanding of electrical engineering, mechanical design, energy efficiency including compliance with Title 24 Energy Standards, and experience with the design of all-electric systems for space conditioning and water heating. In all cases, it is the responsibility of the Design Professional of Record, with the support of the entire project team, to apply all available energy efficiency and electric load minimization practices.

Review of All-Electric Feasibility

Review of All-Electric Feasibility is a document that addresses three questions:

   °   What specific constraint causes all-electric design to be physically or technically infeasible, but does not apply to mixed-fuel?

   °   Can the constraint be resolved?

   °   Is the area and system proposed served by gas piping systems ready for conversion to all-electric in the future, and constructed to provide equivalent health, safety and fire protection?

To address these questions, a Review of All-Electric Feasibility must include:

   •   Identify the physical or technical constraint: Document the specific physical or technical issue that results in the infeasibility of All-Electric design of the project.

   •   Identify alternatives: Based on review of plans, calculations, and supporting documentation, identify methods, equipment, and design features available to resolve the physical or technical issue to mitigate infeasibility.

      °   Efficiency: Where the issue relates to peak electrical load, energy efficiency construction practices, design options, and compliance credits can commonly contribute to resolving the issue. For the all-electric design, confirm all available compliance credits have been applied. Confirm all available energy efficiency design and construction practices have been applied to all building features contributing to loads regulated by Title 24 Energy Standards. Confirm equipment specified is no less efficient than prescriptive baseline specified by Title 24 Energy Standards.

      °   Mechanical: Review envelope and architectural features and mechanical design are consistent with minimization of load on mechanical equipment. Determine whether space conditioning and water heating electric peak load can be reduced via piping or plumbing design, equipment sizing, equipment layout, or substitution of equipment type. Mechanical equipment must be no less efficient than electric prescriptive baseline, where such a baseline is provided by Title 24 Energy Standards. 2

      °   Electrical: Review electrical panel schedule and load calculations for the all-electric design. Confirm connected electrical load and demand electric load for the all-electric design are calculated in accord with California Electrical Code, and are consistent with the design for compliance with Title 24 Energy Standards.

      °   Provide documentation of examples of all-electric design and construction of similar systems and circumstances.

   •   Document Available Solutions: Review the mixed-fuel design, and document the specific area and system proposed as mixed-fuel. Confirm that the physical or technical constraint will specifically be resolved by granting an exception allowing mixed-fuel construction of the area and system. Confirm proposed gas piping systems, fixtures, and infrastructure are limited to the system or area of the building for which All-Electric design is infeasible.

   •   Apply Electric Ready Design Guidelines: Areas served by gas piping systems, fixtures, and infrastructure must prepare for future retrofit to all-electric by installing sufficient electrical conductors and raceways, bus bar capacity, and overcurrent protection, and providing sufficient space and drainage for future replacement of gas systems with electric. Reviewers shall affirm that the project design conforms to the relevant provisions of Electric Ready Design Guidelines to the extent feasible.

   •   Recommendation Regarding Health, Safety, and Fire Protection: Review construction methods, safety equipment, and design features proposed. Recommend specific design features, equipment, and construction practices sufficient to ensure the project’s modified design provides equivalent fire protection and health and safety to all-electric design.

   •   Documentation of the above via a report addressing each item above in detail.

Review documentation must be incorporated into plans, with signature by a reviewer for each discipline (electrical, mechanical, and architectural/Title 24), and stamp by the Design Professional of Record.

QUALIFICATIONS FOR ALL-ELECTRIC FEASIBILITY REVIEWERS

All-Electric Feasibility Reviewers must apply specialized knowledge and experience in the application of energy efficiency design and construction; compliance of all-electric systems with Title 24 Energy Standards, and experience with the design of all-electric systems for space conditioning and water heating. The review team must include each of the following:

 

Item	Qualification	Minimum Experience
1	Licensed Professional Engineer with Mechanical Specialty	Design and demonstration of compliance for at least one all-electric project which is: •   Either multifamily (3 or more housing units), or commercial (minimum of 10,000 square feet floor area);    AND •   Either    -   Construction of a new building, OR    -   Alteration where scope included replacement of space conditioning and water heating systems.
2	Licensed Professional Engineer with Electrical Specialty
3	California Association of Building Energy Consultants – Certified Energy Analyst	Title 24 documentation accepted for compliance for at least one all-electric new construction project of the same or similar occupancy to the project under review.

 

Each of the above disciplines must be represented by a third-party, i.e. individuals not employed by a company responsible for the design or construction of the project.

Due to the qualifications required, review is expected to be performed by a team, but individuals holding multiple qualifications may serve more than one role.

Process for Physical Constraint in Small Infill Sites: Projects seeking exception on the basis of Physical Constraint in a Small Infill Site (Category C above):

   •   Persons responsible for the design of the project may be responsible for preparation of the review.

   •   Reviewer(s) must include a minimum of two disciplines:

      °   Licensed Professional Engineer with Electrical Specialty, AND

      °   Either Licensed Professional Engineer with Mechanical Specialty, or CABEC Certified Energy Analyst.

   •   The Review for All-Electric Feasibility must address each of the considerations in the Review for All-Electric Feasibility section above.

4)   SUBMITTALS REQUESTING EXCEPTION ALLOWING A MIXED-FUEL BUILDING SYSTEM OR AREA

If an exception to San Francisco Building Code Section 106A.1.17.1 is granted due to infeasibility, supplemental documentation is required:

   •   Project Submittals: Installation of gas infrastructure and piping systems is strictly limited to the system and area of the building for which all-electric design is infeasible, or systems not specifically regulated by San Francisco Building Code 106A.1.17.1. Project submittals providing any construction detail related to piping systems or mechanical system design must be consistent with all-electric design and construction for all systems and areas excepting the area and system determined to be infeasible.

   •   Energy Standards: Newly constructed buildings are subject to local energy design requirements stricter than California Title 24 Building Energy Efficiency Standards, including provisions specific to Mixed Fuel buildings. See Administrative Bulletin 93 for details.

PERMISSION TO CONSTRUCT A MIXED-FUEL BUILDING DUE TO INFEASIBILITY

San Francisco Building Code Section 106A.1.17.1 allows the approval of an exception allowing issuance of a permit to construct a new mixed-fuel building only on a case-by-case basis. In order to obtain an exception to San Francisco Building Code Section 106A.1.17.1, the applicant must:

   1.   Complete a Review of All Electric Feasibility. This review must be completed by a third party; individuals employed by a company responsible for the design or construction of the project may only prepare the review in the case of Physical Constraint in Small Sites (Category C). Review of All Electric Feasibility documents the specific area and system proposed to be constructed as mixed-fuel and the basis for a determination all-electric design is infeasible.

   2.   Submit a Request for Approval of Local Equivalency for Modification or Alternate Materials, Design, or Methods of Construction (Administrative Bulletin 005), including two copies of the following documentation of the proposed modification to materials and methods of construction:

      a.   Project plans specifying the area and system proposed for mixed-fuel construction

      b.   Review of All Electric Feasibility

      c.   Acknowledgement of energy performance requirements that apply to mixed-fuel design (see Administrative Bulletin 93)

      d.   Affirmation of the specific provisions of Electric Ready Design Guidelines (Attachment 1) that pertain to the area and system of mixed fuel construction. If it is not feasible for the mixed-fuel area or system to fully comply with the guidelines, the project sponsor shall specify the extent to which the guidelines are feasible.

   3.   Review meetings will be conducted by the Department of Building Inspection, with the Department of Environment and the Fire Department where applicable, to consider the request for approval of Request for Approval of Local Equivalency for Modification or Alternate Materials, Design, or Methods of Construction (Administrative Bulletin 005). Attendance at such review meetings will include, at a minimum, the Design Professional of Record, the project mechanical engineer, and the All Electric Feasibility Reviewers.

   At such meetings, it is the responsibility of the project applicant to demonstrate infeasibility. Staff will

      •   Review plans, calculations, and supporting documentation for all-electric options demonstrate all available energy efficiency features, practices, and credits for third-party reviews specified by the California Energy Commission contributing to compliance with Title 24 Energy Standards were applied to the all-electric option.

      •   Review alternative technologies and approaches considered prior to the All Electric Feasibility Reviewers making a determination.

      •   Review the mixed-fuel design, including the specific area and system served by gas piping systems, fixtures, and infrastructure

      •   Review conditions proposed to ensure the project’s modified design provides equivalent fire protection and health and safety to all-electric design.

   The request will either be:

      •   Approved with conditions by DBI with concurrence by Department of Environment,

      •   Placed on “hold” pending submittal of additional information, or

      •   Disapproved.

   Determinations as to infeasibility may be appealed to the Board of Examiners, as established under Section 105.1 of the San Francisco Building Code. See https://sfdbi.org/board-examiners for details.

   The project sponsor is responsible for the hiring of Third Party Reviewers from the list of approved All-Electric Third Party Reviewers maintained by the Department of Building Inspection. The project sponsor is responsible for all costs related to All Electric Third Party Review.

   Plan review fees are required to be paid as noted in Administrative Bulletin 005.

   4.   Upon approval to construct a mixed-fuel building, a copy of the signed form approving the equivalency and indicating all conditions of approval will be part of the permanent record of the project, and a copy will be sent to the project sponsor. The project sponsor shall include all specified conditions in plans.

PERMISSION TO CONSTRUCT A MIXED-FUEL BUILDING THAT INCLUDES COMMERCIAL FOODSERVICE

Applications for permit for new construction proposing to install gas piping systems, fixtures, and infrastructure exclusively for cooking equipment within the area designated for commercial food service must include the Application for Exception for Commercial Food Service (Attachment 3), and any foodservice areas where such systems, infrastructure, and fixtures are approved installed must be indicated on all addenda and the Final Compliance Verification form (Attachment 2).

PROJECT COMPLETION

Final compliance verification documentation (Attachment 2) is required prior to final inspection. No final Certificate of Completion may be issued until All-Electric Ordinance: Final Compliance Verification has been received, reviewed, and accepted by the Department of Building Inspection.

Failure to ensure the project is designed and constructed in a manner consistent with an exception and conditions approved will subject the project to all of the enforcement and abatement remedies detailed in the San Francisco Building Code.

LIST OF ALL-ELECTRIC FEASIBILITY REVIEWERS

The Department of Building Inspection with the assistance of Department of Environment shall conduct an Open Call for Interest and Qualification to Review All Electric Feasibility to identify professionals with specialized knowledge and experience in the application of energy efficiency design and construction; compliance of all-electric systems with Title 24 Energy Standards, and experience with the design of all-electric systems for space conditioning and water heating. Department of Building Inspection shall provide upon request a list of individuals who have provided evidence of holding such qualifications. Review of All-Electric Feasibility will only be considered when prepared by an individual holding the appropriate qualifications; selection of reviewers not specifically listed shall require submission of information to the Department of Building Inspection establishing the qualifications of each reviewer. Submittal of substantially inadequate or incorrect analysis will be grounds for removal from the list of qualified reviewers.

Originally signed by:

Patrick O’Riordan      3/5/2021

Interim Director

Department of Building Inspection

Approved by the Building Inspection Commission on January 20, 2021

_________________________

1 The linear footage of street frontage is calculated by adding the lengths of all property lines directly adjacent to the right of way.

2 Mechanical equipment is not required to be more efficient than US DOE Appliance and Equipment Standards applicable to the specified device, provided all options are exhausted regarding piping or plumbing design, equipment sizing and layout, and substitution of alternative equipment types.

Attachment 1:    Design Guideline for Electric Ready Buildings

Attachment 2:    Final Compliance Verification

Attachment 3:    Application for Exception for Commercial Food Service

Attachment 4:    Application for Review of Pre-Existing Agreement

Attachment 5:    Summary of Investor-Owned Utility Options for Proposed Electric Load Exceeding Capacity of Utility Infrastructure