CSAC Comments on Issues Regarding the Rule 20 Utility Undergrounding Tariff Program
October 8, 2020
CSAC has filed and served comments in response to an email ruling issued by the California Public Utilities Commission (CPUC) Administrative Law Judge (ALJ) on September 3, which asked parties to comment on several issues related to the CPUC Staff Proposal for the Rule 20 utility undergrounding tariff program, in light of recent developments related to the COVID-19 pandemic.
The CPUC released the Staff Proposal for revisions to the Rule 20 program in February, and CSAC filed and served comments in response to it in April. A summary of CSAC’s initial response to the Staff Proposal is available in this bulletin article.
CSAC continues to support the Rule 20A program with some modifications to address the policy concerns raised in the CPUC Staff Proposal. CSAC remains strongly opposed to the Staff Proposal’s recommendation to sunset the Rule 20A program and to replace it with a modified Rule 20B program with tiered ratepayer contributions. The proposed ratepayer contribution would create additional barriers for historically underserved communities in completing undergrounding projects.
CSAC is also concerned with the accelerated timeline summarized in the Staff Wind Down Implementation Proposal for Rule 20A included in ALJ’s September 3 email ruling. However, if the CPUC decides to move forward with the wind down implementation proposal, CSAC asks that the CPUC consider the following requests:
- Delay execution of the Staff Wind Down Implementation Proposal
- Set timeline to form an underground district to be no less than 18 months
- Allow work credit trading among local governments
- Require utilities to submit Tier 2 Advice Letter publicly
Finally, while there is evidence that counties are facing significant economic challenges due to the pandemic-induced recession, the specific revenue impacts across all local jurisdictions in California remain unclear. Accordingly, it is too early to make significant changes to the Rule 20 program based on the perceived economic impacts of the COVID-19 pandemic, especially if any such changes would require greater contributions of funding from local governments in order to complete undergrounding projects.
A full copy of the comments CSAC submitted in response to ALJ’s September 3 email ruling is available here.
CSAC will continue to keep counties informed on any new developments related to the proposed Rule 20 reform.