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May 12, 2025 VIA ELECTRONIC MAIL The Honorable Marvin A. Blyden Chairman Committee on Housing, Transportation & Telecommunications 36th Legislature of the Virgin Islands Capitol Building, P.O. Box 1690 St. Thomas, U.S. Virgin Islands 00804 Re: Hearing – Quality of Telecommunications and Broadband in the Territory May 14, 2025 Dear Chairman Blyden: In response to your request for a testimony on various matters, please find attached the testimony of the Virgin Islands Water and Power Authority regarding the challenges and coordination efforts between telecommunications providers and government agencies. These include matters such as permitting, access to poles and conduits, and customer service-related issues. Sincerely, Karl Knight Chief Executive Officer/Executive Director CC: Dionne Sinclair, General Counsel, Virgin Islands Water and Power Authority Shanell Petersen, Director of Communications, Virgin Islands Water and Power Authority TESTIMONY OF THE VIRGIN ISLANDS WATER AND POWER AUTHORITY WAPA’s Role in Telecommunications and Broadband Infrastructure Committee on Housing, Transportation & Telecommunications May 14, 2025 Introduction Good morning Honorable Chairman, Senator Marvin Blyden, as well as other esteemed members of the Senate present, testifiers, the listening and viewing audience, and the WAPA family. I am Karl Knight, Executive Director and Chief Executive Officer of the Virgin Islands Water and Power Authority, often referred to as “WAPA” or “the Authority.” I thank you for the opportunity to appear before you today to discuss WAPA’s role as it relates to the quality of telecommunications and broadband in the Territory. Simply put, WAPA continues to actively support the expansion of critical telecommunications and broadband infrastructure within the Territory. Further, the Authority understands the profound impact these services have on the daily lives of Virgin Islanders and their significance in crucial sectors such as education, healthcare, commerce, and emergency response. WAPA’s Role: Proactively Improving Practices & Modernizing Oversight WAPA’s role is fundamentally one of support. The Authority provides equal access to poles, approximately 40,000 territory-wide, and infrastructure so that licensed telecommunications and broadband providers can deliver reliable service to the public. However, this support must come with oversight to ensure the integrity, reliability, safety and federally funded requirements of the electric system that serves every resident and business. Infrastructure Mapping and Accountability To better manage attachments to our system, WAPA contractors are substantially completed and is coordinating the final transfer of a multimillion-dollar Geographic Information System (GIS) study. The GIS updates the Transmission and Distribution field inventory and mapping system. The GIS serves as the basis for accurate Damage Assessments, proper analysis for Hosting Capacity Studies (for alternative energy), Line Loss efficiency studies, crucial data for Mitigation Planning projects, Dispatch/Outage Management systems and aids in day-to-day operational planning. This study provides a detailed inventory of what is currently attached to WAPA poles and helps determine what equipment can safely be supported moving forward to ensure the integrity of the pole. Process For Attaching - Pole Safety and Engineering Requirements Before any equipment can be attached to the Authority’s poles or infrastructure, the Licensee must complete a pole attachment application. This application must detail the items to be attached, including technical specifications and the number of poles involved. Following the submission, an assessment will be conducted to ensure that the proposed attachments are safe and compliant with legal standards. This assessment allows the Authority to review the items in the context of the pole's composition and existing attachments. The proposed equipment must not compromise the integrity of the pole, especially during extreme weather conditions. Upon completion of the assessment, the Licensee will be notified of any necessary preparatory work before attachment. Where needed, pole upgrades or reinforcements must be made. Wind loading is especially critical in our hurricane- prone region. Unauthorized attachments and undocumented equipment installation are no longer tolerated under the new data-backed system, with active audits and enforcement measures already underway. Moving forward, all attachments must be submitted for approval and undergo proper engineering assessments with clear timeframes. Composite Poles and Warranty Protection WAPA employs a combination of traditional wooden poles and advanced composite poles. With each composite pole valued significantly higher of a wooden pole, a controlled process is essential to preserve their warranties and maintain the long- term cost-benefit decision tied to FEMA-backed resilience mandates. Consequently, it is imperative that Licensees strictly follow the manufacturer’s guidelines to prevent any potential warranty voidance and secure storm-hardening initiatives. Other Infrastructure Considerations In addition to supporting telecommunication equipment, WAPA’s poles host critical public safety systems like, an acoustic sensor system that detects and locates gunshots to help law enforcement respond quickly. It is essential that these attachments are managed in a coordinated and methodical manner to prevent any potential interference and ensure smooth operation. Compliance with National Safety Codes Licensees are also required to comply with all electrical and other safety standards as well as federal requirements for their installations and equipment operation, including the National Electrical Safety Code. For example, RF-emitting devices must include disconnect mechanisms and continuous exposure monitoring to permit technicians and lineworkers to be able to work safely on the poles where these devices are located. We remind this Body that ACT 7240 mandate WAPA to provide an in-kind match totaling $15,500,000 to secure the federal broadband grant. As part of this mandate, WAPA and viNGN entered into a Memorandum of Agreement on September 30, 2011. This agreement outlines the specific resources to be provided by WAPA for the Project, including the usage of certain underground fiber and infrastructure. Under the September 2011 MOA, WAPA is precluded from engaging in the telecommunications business as a middle mile or last mile provider, ensuring it does not compete with viNGN and supports the stated public goals of the Project. Additionally, viNGN is granted sole and exclusive use of specific underground conduits owned and controlled by WAPA, which forms a significant part of the match resources. Conclusion WAPA is a partner in supporting telecommunications and broadband development while also ensuring public safety. WAPA must safeguard that pole attachments do not put the utility’s system at risk. The utility infrastructure is critical to the health and safety of our community. Again, I thank the Senate and the public for the opportunity to discuss WAPA’s support for telecommunications and broadband in the Territory. To the extraordinary men and women of the WAPA family — thank you for showing up with heart, strength, and a spirit of service that lifts our entire community. The WAPA team is available for questions.