innovative
solutions
engineering
inc.
Expert Engineering Report
and Opinion for the
Design and Installation of
Single Use and Joint Use
Wood Pole Lines in
New Brunswick
by Ernst H. Wiebe, P. Eng.
Innovative Solutions Engineering Inc.
174 Moir Avenue * Winnipeg, MB * Canada * R2K 0G9
T: (204) 898-0974 « E: isengine@gmail.comReport on Single Use and Joint Use and Overhead Wood Pole Lines in New
Brunswick
This expert opinion is that of the author, E. H. (Ernst) Wiebe, P. Eng., of
Innovative Solutions Engineering Inc. The author has over 35 years of electric
utility Distribution Engineering experience. Until early June, 2015, he was the
Chair of the CSA Standards Technical Committee on Overhead Systems, a key
component of the Canadian Electric Code, Part Ill. He held this position for over
20 years and recently resigned from it to enable him to Chair the more senior
GSA Strategic Steering Committee on Power Engineering & Electromagnetic
Compatibility. He is a member of 20 CSA Steering Committees, Technical
Committees and Subcommittees that cover a broad scope of equipment and
system Standards used by telecommunication and electric utilities in Canada and
North America. Please see Appendix A for the Curriculum Vitae of the author.
NB Power had requested a review and evaluation of wood pole lines in New
Brunswick, in single use and joint use. To that end, the author completed pole
verification audits of two Rogers-owned single use lines and a section of one NB
Power joint use line. The results of the audits are in Appendix B.
Facts and Assumptions
1) Both single use and joint use lines, irrespective of owner, must comply with the
tequirements of the Canadian Electrical Code, Part Iil, CSA Standard C22.3 No.
1 “Overhead Systems’. It is assumed that the lines were designed and installed
when the 2006 edition was current. The 2010 edition is now current and will be
superceded by the 2015 edition later this year. The requirements of the 2010
edition are identical to that of the 2006 edition with regard to minimum clearances
and pole strengths of wood pole lines.
2) The Canadian Electrical Code for overhead systems, requires joint use lines to
also meet the requirements of CSA Standard C22.3 No. 5.1 where possible.
3) According to CSA C22.3 No. 5.1, the messenger of the communication circuit
on a joint use line is to be bonded to the neutral of a multi-grounded neutral
system at least every 300m.
4) Alongside land likely to be travelled by road vehicles or within the limits of
streets and highways, the minimum CSA Standard ground clearance
requirements of ice-loaded communication conductors are the same as that of
electric utility neutral or secondary conductors, namely 4.42 metres.
5) The messenger and communication conductor lashed to the messenger are
the same for both Rogers-owned wood pole lines.6) NB Power wood pole lines are designed and installed according to the NB
Power Standard Construction Practices, which are based on the Canadian
Electrical Code.
Observations
41) The poles utilized in the Rogers-owned single use lines are predominantly 35
foot in length and all are Class 5 in strength. It appears that 100% of the line
between Fredericton and Minto consists of such poles, whereas greater than
75% of the line between St. Leonard and St. Quentin consists of such poles.
2) The joint use NB Power wood pole line, from which the single use Rogers-
owned line between Minto to Fredericton continues, consists primarily of wood
poles 40 feet in length, although 35 foot poles exist. The 36 foot and 40 foot
poles are Class 6 in strength.
3) The line between St. Leonard and St. Quentin suffers from inadequate
understanding of the requirements of CSA Standard C22.3 No. 1 by either the
designer or the installer, or both. Apparent clearance violations were observed in
numerous locations
Discussion of the Observations and the Canadian Electric Code
requirements of single use and joint use wood pole lines in New Brunswick
1) Use of 35° Class 5 poles by Rogers and NB Power
Clearly, the preferred pole utilized in the Rogers-owned lines is the 35' Class 5
pole. One line consisting of 167 poles is 100% 35', Class 5 wood poles. The
other line, consisting of 341 poles, is at least 75% such wood poles. These poles
are the same length and class of wood poles to that used by NB Power in single
use and some joint use lines. This is common practice not only in New Brunswick
but in other areas of Canada — particularly in single use electric utility pole lines.
In Appendix C, it is shown that 35’ poles provide adequate room for single phase
or three phase electric single use only lines. If minimum CSA requirements are
used for the design, 35° poles could even provide room for some joint use
applications. It can also be shown that the loads on poles in common single
phase or three phase, single use electric applications can be adequately
supported by Class 5 poles.
2) Design of Rogers-owned lines in New Brunswick
Based on the variations in span length and attachment height of the messenger
on the Rogers-owned lines in New Brunswick, itis not clear what ruling span,minimum ground clearance, etc. the design called for. In order to determine the
attachment height to accommodate the minimum ground clearance required by
CSA Standard C22.3 No. 1, a designer would have to know:
a) the nature, ie. the CSA category, of land being crossed by the
lines
b) the minimum ground clearance, according to CSA, for that category of
land;
) the ruling span of the line and individual actual span lengths;
d) the weather loading required for the land being crossed;
e) the variation in terrain elevation in each span;
f) the makeup and attributes of the lowest conductor;
g) the desired installed tension of the conductor,
h) the maximum loaded sag of the conductor;
i) the expected mean annual maximum snow for the geographic region
the line is in
The actual attachment heights varied from 0.3m to approximately 2m ftom the
top of the pole. The span lengths varied from 66m to 153m in length in one line.
On a 150m span of 35' Class 5 poles, a sag of almost 2m was measured. While
the resulting ground clearance of 5.8m at this location appeared to be more than
adequate, it demonstrates that a small, light communication conductor lashed to
a messenger sags substantially even without ice. However, when a ground
clearance of 4.57m is measured, itis likely that such a span violates the
minimum Code requirement of 4.42m alongside highways accessible to vehicles
under maximum loaded (icing) conditions that produce the maximum loaded sag
As far as strength is concerned, all of Rogers-owned line poles are Class 5 or
stronger.
3) Additional requirements for single use and joint use lines
‘As demonstra, designing and building wood pole lines requires considerable
knowledge and experience. There are a number of other clearances that come
into play if the line is to be installed in proximity to buildings, railways, ete. It is
imperative that the requirements spelled out in the Code, CSA C22.3 No. 1, are
understood well
Clearances and separations applicable to overhead lines are not to be
considered as the preferred, but the minimum. Clause 5.2.1 — titled
Construction and day-to-day clearances states, " The clearances specified in
Clause 5 for wires and conductors are minimum values related to maximum
specified loads and service conditions and represent design limits rather than
clearances for construction or day-to-day operation. Clearances under day-to-
day conditions are greater than the minimum clearances specified in Clause 5 to
ensure that the actual clearances under maximum specified loads and service
conditions meet minimum clearance requirements.”The clearance values in the Code are minimum for design purposes. Actual
measurements should be greater to ensure that the minimums are never
violated
Another example is the requirement for bonding the communication messenger
to the electric utility's multi-grounded neutral on joint use lines. The Code calls up
CSA C22.3 No. 5.1 in this regard. Clause 4.5.1 of this Standard states, “Bonding
of the communication plant to the multigrounded neutral of the supply system at
appropriate intervals as described in Clause 4.2 shall be the principal source of
ground. Itis permissible and desirable to supplement this source of ground with
grounding electrodes that are part of the communication system grounding.” It
needs to be noted that additional communication grounding electrodes, if
installed, must also be connected to the multigrounded neutral system to mitigate
the potential for hazardous voltages.
On joint use lines, the electric utility neutral is a very important part of the
communication system. Bonding the messenger to it at regular intervals prevents
a difference in voltage on the pole that could harm communication workers and
electric workers while performing their duties on the line. While electric workers
are trained and equipped to deal with the voltages on the line, the communication
workers are not.
Also, the regular bonding reduces the amount of induced current flowing in the
messenger. If the bonds did not exist, the induced current from the electric lines
onto the messenger would have to flow until it was diverted to ground through a
pole ground connected to the electric multigrounded system. Without the neutral,
that runs uninterrupted along the whole line, connecting all the individual pole
grounds on the line and mitigating local issues, localized high voltages could
appear on a pole. Now, since the ground wires travel down the pole to the
ground, these voltages become a concem for the public as well as the workers,
The Standard recommends additional communication grounds, but not in lieu of
the multigrounded neutral system, and, these must be interconnected with the
multigrounded neutral to ensure that workers and the public aren't presented with
potentially harmful voltages.
The Canadian Electric Code, including CSA Standard C22.3 No. 1 and CSA
Standard C22.3 No. 5.1, was developed by a group of engineers that included
technical experts from Communication Utilities and Electric Utilities. Today, these
Standards are still maintained by such a group of technical experts from these
utilities. This requirement is a practice that must be followed in Canada. The
safety of workers and the public depends on itConclusions
1) Rogers-owned single use wood pole lines in New Brunswick consist primarily
of 35! wood poles. All wood poles are Class 5 strength or stronger.
2) Single use electric utility lines (NB Power's and those of the rest of Canada)
are capable of, and actually do, employ the same 35’ Class 5 poles for single
use lines.
3) Some joint use applications can be accommodated by lines consisting
primarily of 36’ Class 5 poles
4) In designing and constructing wood pole lines, attention to the requirements of
the Canadian Electric Code, Part Ii, is critical for safety of the public and
workers.
5) The clearance and separation requirements spelled out in the Code (CSA
22.3 No. 1) are minimum values for design purposes. Day-to-day and
measured values must be greater to ensure the minimums under fully loaded
conditions are met.
6) The electric utilty’s neutral is critical to the safe operation of communication
Circuits on joint use Wood pole lines.Appendix ACurriculum Vitae
Ernst H. Wiebe, P. Eng.
Emst H. Wiebe, P. Eng,
Professional Engineer
Employed by: Innovative Solutions Engineering Inc.
174 Moir Avenue, Winnipeg, MB Canada R2K 0G2
Position: _ President, innovative Solutions Engineering Inc., Winnipeg, Manitoba
Date of 1952 05 18
Nationality: Canadien
Expertise: Electric Distribution Utiity Engineering - including the development and
interpretation of standards, the planning, design, protection; and, the specification
of materials and facilities for 69 kV overhead and underground systems.
‘Membership in Professional Societies:
‘Association of Professional Engineers and Geoscientists in the Province of Manitoba
(APEGM)
Institute of Electrical and Electronics Engineers (IEEE)
Past Memberships in Technical Organizations:
Centre for Energy Advancement through Technological Innovation (CEATI Intemational)
= Charter Member and former Chair, Distribution Assets Life Cycle
Management R&D Interest Group
Canadian Electricity Association (CEA)
- Member, Regulatory innovations Task Group
- Associate Member, Distribution Council
= Member, Task Group on Pole Structures
~ Chair, Joint Pole Use Task Group
~ Member, Standards Management Committee
‘Current Memberships in Technical Organizations:
Canadian Standards Association (CSA)
- Chair, Strategic Steering Committee on Power Engineering & EMC
- Chair, €22.3 No.1 “Overhead Systems" Standard Technical Committee
(until June, 2015)
- Member, €22'3 No. 7 “Underground Systems” Standard Technical
Committee
= Member, C22.2 #129 "Neutral Supported Cables” Technical
‘Subcommittee
= Member, Technical Subcommittee on Distribution Transformers
- Member, C802.1 “Minimum Efficiency Values for Liquie-flled Distrioution
Transformers" Technical Subcommittee
Chair, Technical Committee on Insulated Power Cables
- Member, C68.3 "Shielded and Concentric Neutral Power Cables, Rated
5-45 KV" Technical Subcommittee\EEE
- Member
~ Chair, "DC in the Home” Industry Connections project
Key Qualifications:
Engineering career with Manitoba Hydro for 37 years that included being:
A Distribution Design Engineer, Manitoba Hydro, for 8 years, responsible for
providing engineered designs for new installations, and improvements to,
Manitoba Hydiro's 69 KV and below, overhead and underground, electric
distribution and subtransmission systems.
The Distribution Standards Engineer, Manitoba Hydro, for 18 years, responsible
for design and construction standards, and standard material specifications for
Manitoba Hydro's 69 kV and below, overhead and underground, electric
distribution and subtransmission systems. Refocused the Distribution Standards
‘group into the primary technical resource for Distribution Engineering at Manitoba
Hydro
The Manager, Distribution Standards & Services Department, Manitoba Hydro,
for 4 years, responsible for directing the development of design and construction
standards, and standard material specifications for Manitoba Hydro's natural gas
distribution system and Manitoba Hydro's 69 kV and below, overhead and
Underground, electric distribution and subtransmission systems.
‘The Division Manager, Distribution Planning & Design Division, Customer
Service & Distribution Business Unit (formerly the Transmission & Distribution
Business Unit), Manitoba Hydro, 2005 through 2011, leading the organization
that was responsible for engineering and developing system and material
‘Standards, distribution system performance, system protection, and the planning
and design of Manitoba Hydro's natural gas and Manitoba Hydro's 68 kV and
below, overhead and underground, electric distribution and subtransmission
systems,
Member and current Chair, CSA C22.3 No.1 Technical Committee responsible for the
CSA C22,3 No.1, "Overhead Systems’ Standard which is part of the Canadian Electrical
Code, Part 3. This National Standard details the requirements for all of the above-ground
lines and facilities of electric utilities.
Member, numerous CSA (Canadian Standards Association) Standards Committees and
CEA Purchasing Specification Working Groups, detailing requirements for distribution
and subtransmission materials and equipment such as wire and cable, insulators, poles,
and transformers.
Involved in numerous research and development projects to improve and test designs
and materials for 66 kV and below distribution and subtransmission systems. A charter
member and former Chair of the CEATI Distribution Assets Life Cycle Management R&D.
Interest Group.
Served as an expert witness for BC Hydro and NB Power in legal proceedings involving
their electric distribution systems,Education:
Bachelor of Science in Electrical Engineering (1974) ~ University of Manitoba
Problem Solving and Decision Making ~ Kepner Tregoe ~ 1988
Quality Process Improvement Tools ~ Process Management International - 1998
‘Seven Management and Planning Tools - Process Management Intemational ~ 1998
Leadership Excellence — The Banff Centre, Leadership Development Division - 2004
Leadership Challenge: Managing Change Successfully - The Banff Gentre - 2006
Employment Record:
‘Since 2004: President, Innovative Solutions Engineering Inc., an electric engineering
consulting company
2005 to June, 2011: Division Manager, Distribution Pianning & Design Division,
Customer Service & Distribution (formerly Transmission & Distribution) - Manitoba Hydro,
Winnipeg, Canada
Responsible for leading the organization responsible for the engineering ~
standards, planning and design - of Manitoba Hydro’s natural gas and electric,
distribution and subtransmission systems.
2001 to 2008: Manager, Distribution Standards & Services Department - Manitoba
Hydro, Winnipeg, Canada
Responsible for directing the development and maintenance of Manitoba Hydro's
natural gas and electric (66 kV and below), overhead and underground, design
and construction standards; the specifications forall related standard materials;
the approval of the manufacturers and their products for these materials
1992 to 2001: Distribution Standards Engineer - Manitoba Hydro, Winnipeg, Canada
Responsible for the development and maintenance of Manitoba Hydro's 66 kV
and below, overhead and underground, design and construction standards; the
specifications for all related standard materials; the approval of the
manufacturers and their products for these materials,
1986 to 1992; Distribution Standards Design Engineer - Manitoba Hydro, Winnipeg,
Canada
Updated the Manitoba Hydro 25 KV Distribution Standards to Incorporate
changes to national Standards and voltage levels up to 66 KV.
1985 — 1986: Design Engineer, Stations Department, Manitoba Hydro, Winnipeg,
Canada
Responsible for designing modifications to distribution stations, 66 kV
and below, to enhance structure and equipment clearances, for the
installation of control equipment and the egress of electric feeder circuits.
1977 ~ 1988: Design Engineer, Distribution Engineering, Manitoba Hydro, Winnipeg,
Canada
Responsible for the design of new, and enhancements to existing, overhead and
underground lines, 66 KV and below, and estimating the cost of these
installations10
1976 - 1977: Apparatus Maintenance Engineer, Electrical Maintenance Department
Manitoba Hydro, Winnipeg, Canada
Responsible for the development of maintenance requirements for high-
voltage cireuit breakers
1974 ~ 1976: Engineer-in-Training, Manitoba Hydro, Winnipeg, Canada
Awards and Special Assignments:
Presenter and co-author, “Collaring the Costs of Distribution Substations” paper,
DistribuTECH Automation and Technology Conference, San Diego, California, January,
2005
USS, Patent No. 6,770,810 "High voltage electrical handling device enclosure", awarded
by the U.S Patent and Trademark Office, August, 2004, as co-inventor. “An enclosure
provided for a high voltage electrical handling device, for example a transmission
transformer, ... permits the equipment to be supported on the ground without the
necessity of elaborate protection systems as found in typical electrical power switchyards
or substations.”
Canada Patent No. 2375584 "High voltage electrical handling device enclosure’,
awarded by the Canada Patent Office, January, 2008, as co-inventor.
Canadian Standards Association AWARD OF MERIT, for significant contribution and
stralegic leadership in the development of key standards related fo elecirical engineering
and the Canadian Electrical Code Part lil, in June, 2003,
Represented the Canadian Electricity Association to the Ontario Eneray Board regarding
the Canadian experience and the application of CSA Standard C223 No. 4 “Overhead
Systems’ to the joint use of electric utility poles with Cable TV and other
telecommunications companies in October, 2004
Represented the Canadian Electricity Association to the Electric Distributors Association
‘of Ontario and the Electric Safety Authority of Ontario in discussions regarding the
proposed regulation of safety in electric distribution utilities of Ontario in
November/December, 2001
Key Session Presenter, National Electric Utilities Standards Seminar, Edmonton, Alberta
in May, 2000, on the CSA G22.3 No.1 “Overhead Systems” Standard. The session was
attended by utlity engineers, consulting engineers and electrical contractors of Alberta
Represented the Canadian Electricity Association to the U.S. Dept of Eneray and later
the Distribution Transformer Committee of NEMA (National Electrical Manufacturers
Association, an organization of primarily U.S. manufacturers), on energy efficiency issues
in Canada regarding distribution transformers in Spring, 1999.
Prepared expert opinions in 2004 - Pritchard v. BC Hydro and Wetford v. BC Hydro and
in 2012 ~ Tanner Joseph Bendzak v. Floyd Winston Bohnet, Julie Christine Bohnet,
Connor Bohnet and British Columbia Hydro and Power Autharity
Prepared expert opinion and served as expert witness in 2007 - Marguerite Cormier v,
New Brunswick Power Distribution and Customer Service Corporation,"1
Prepared expert opinion and served as expert witness in 2012 — Paul Campbell v. NB.
Power Distribution and Customer Service Corporation (‘NB Power’) and Lakeside
Enterprises Ltd
Prepared expert opinion in 2014 - Robert Armstrong and Karen Armstrong v. New
Brunswick Power Holding Corporation, New Brunswick Power Transmission Corporation,
and New Brunswick Power Distribution and Customer Service Corporation
Organized the IEEE “DC in the Home” project for IEEE Standards Activities ~ Industry
Connections.
Languages:
Speaking Reading Writing
English Excellent Excellent Excellent
German Good Excellent Good
Publications:
“Distribution Polymeric Cable Systems", GEA SD 117, Co-author
Patents:
U.S. Patent No. 6,770,810 “High voltage electrical handling device
enclosure’, August 3, 2004 — Co-Inventor
‘Canada Patent No. 2375584 High voltage electrical handling device
enclosure’, January 5, 2009 - Co-inventor
Certification:
|, the undersigned, certify that to the best of my knowledge and belief, these biographical
data correctly describe myself, my qualifications, and my experience,
Date: June 3, 2015
(EH. Wiebe, P. Eng.)Appendix B13
Pole Verification Audit by Innovative Solutions Engineering Inc.
2015 08 26 — St. Leonard to St. Quentin
(assisted by NB Power staff)
In all, 44 poles, of a total of 341, were verified; 18 span lengths were measured;
and, 3 measurements of ground clearance were taken.
Pole #'s verified
8-35 C15
9-35 C15
~span length — 153m
10-35' CIS
— span length — 152m
11-35" CIS.
70-35 CIS
span length — 148m
71-38 CIS
= span length — 146m
72-35' C5
118 -35' C5
119 - 30' CIS
120 - 30' CI
121-30 CIS
122 - 30° CI5
123 -30' C6
124-30 CIs
125 - 30° CIS
126 - 30' CIS
127 — 30' C15
128 — 35' CIS
154 —30' CIS
— span length — 97m
155 — 30° C15
— Span length — 98m
156 — 30° CIS
= span length — 102m
157 - 30' CI
191-30 C15
= span length — 83m
192-30 CIS
— span length — 95m; 16° clearance to ground at mid-span
193 30' C15
210-30' CI14
211 -30' Cis
~ span length - 96m
212 -35' CI5
— span length - 94m
213 - 35' CI
~ span length - 86m
214 - 35' CIS
268 - 40' Ci3
269 - 30' CI
~ span length - 68m
270-35' CIS
span length — 66m
271 -35' CIS
~ span length - 67m
272-35' CIS
294 — 35' CI5; 25’ clearance to ground at pole
~ span length — 151m
~ 19° clearance to ground at mid-span
295 - 35° CIS
296 — 35° CI
— span length — 150m
297 -35'Cl
= span length - 153m
298 - 36° CI
—span length — 152m
299 - 35' CIS
300- 35° CIS
301 - 35° CI
302-40 CI3
Observations
1) Based on a 2008 12 11 NB Power pole line survey and this verification audit,
at least 268 of 341 poles (>75%) are 35' CI5 or higher. All poles are Class 5
strength or stronger.
3) Either the designer or installer, or both, were not aware of good line
design/construction practices nor of the requirements of the Canadian Electric
Code, Part lil, CSA C22.3 No.1 “Overhead Systems”
- Erratic span lengths for no apparent reason were observed — from 66m
to 153m and in between. No evidence of a ruling span.
- Attachment heights varied from 1 foot below top of pole to 6 feet below
top of pole.
- At times, these two factors combine to result in clearances that appear to
be less than required by Code.15
Pole Verification Audit by Innovative Solutions Engineering Inc.
2015 05 27 — Fredericton to Minto
(assisted by NB Power staff)
In all, 15 poles, of a total of 167, were verified and 7 span lengths were
measured.
Pole #’s verified
4-35'CI5
38 - 35° CI5
~ span length — 57m
39-36 CI
—span length — 60m
40-35' CIS
70 - 35° CI5
78 -35' CIS
— span length — 80m
79-35' CIS
— span length - 77m
80 - 35° CIS
81-35' CIS
145 - 35' CIS
152-35' CIS
— span length — 56m
153 - 35' CIS
~ span length - 75m
154 —38' CIS
—span length — 56m
155 — 35' CI5
167 - 35° CIS
Observations
1) All poles verified were 35’ CIS. Even Stub poles across the road were 35’ CIS.
There were no obvious examples of poles of a different height.
2) Span lengths were more consistent - between 56m and 80m,
3) No ground clearance measurements were takenAppendix C7
ht Calculation — Single Use Electric Utility, Single Phase or 3
Phase Pole
Pole Space Requirements:
NB Power Design
1) Burial Depth — 1.8m (35' and 40’ poles - NB Power Standard Construction
Practices — Standard EDS)
2) Minimum Ground Clearance — 3.7m or 4.42m (CSA C22.3 No. 1 Table 2—
depending on category of land)
3) Mean Annual Maximum Snow Depth — 0.8m (CSA C22.3 No. 1—Appendix D,
Table D.1 - for Fredericton)
4) Lowest Conductor Attachment Point — Neutral — (from top of pole) — 1.5m
(NB Power Standard Construction Practices — Standard ED7-1 or ED7-51)
5) Conductor Sag — Maximum Loaded — 60m — 1240mm; 70m ~ 1690mm (NB
Power Standard Construction Practices - 2ACSR Sparrow, Ruling Span 60m,
Standard ED13-68)
Pole Height required — 1.8 + 4.42 + 0.8 + 1.5 + 1.69 = 10.21m
35’ Pole — 10.67m
‘The NB Power design results in 0.46m of useable space. Therefore, 35 foot
poles provide adequate room for NB Power's design of single phase or three
phase single use wood pole lines that call for a 60m ruling span, up to 70m span
lengths, over land alongside land likely to be travelled by road vehicles or with
the limits of streets and highways, in the Fredericton area.
CSA Minimum Clearance Design
4) the same as per NB Power Design
2) the same as per NB Power Design
3) the same as per NB Power Design
4) Lowest Conductor Attachment Point — Neutral — (from top of Pole) — 0.25m —
single phase; 0.65m — three phase. (CSA C22.3 No.1, Table 18)
5) the same as per NB Power Design
Pole Height (Single Phase) required — 1.8 + 4.42 + 0.8 + 0.25 + 1.69 = 8.96m
Pole Height (Three Phase) required — 1.8 + 4.42 + 0.8 + 0.65 + 1.69 = 9.36m
‘The CSA Minimum Design results in 1.3m — 1.7m of useable space on 35 foot
long poles