CSAC Response to CPUC Staff Proposal on Rule 20 Utility Undergrounding Tariff Program
April 23, 2020
Earlier this week, CSAC filed and served comments in response to the California Public Utilities Commission’s (CPUC) staff proposal for revisions to the Rule 20 utility undergrounding tariff program. The CPUC’s staff proposal is available here.
CSAC generally supports refining and expanding the public interest criteria for Rule 20A projects, while retaining the core components of the existing Rule 20A program. Modifications allowing local agencies to move forward with projects for the purpose of increasing safety and reliability will increase motivation for completing projects as well as community support. Moreover, CSAC encourages the Commission to increase transparency as a means of encouraging additional participation. Slight modifications to the existing Rule 20 program could increase flexibility and provide incentives to implement improvements more expeditiously without phasing-out and ultimately eliminating Rule 20A. Slight modifications will be far more successful at increasing undergrounding efforts than the major reform proposed.
A full copy of the comments CSAC submitted is available here.