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.
