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League Submits Comments to the CPUC on Rule 20 Program

April 22, 2020
The League submitted comments to the California Public Utilities Commission (CPUC) regarding their staff proposal for Rule 20 Program Reform and Enhancements. 
The CPUC Rule 20 Program lays out guidelines and procedures for undergrounding overhead electric facilities. Notably, Rule 20A provides cities with work credit allocations that can be used to fund undergrounding projects that meet certain criteria. Over the past several years, the Rule 20 Program has been fraught with issues related to the allocation of work credits and the buildup of unused work credits across the state. The Rule 20 Program has also been criticized for failing to focus on undergrounding projects designed to improve safety, such as wildfire mitigation and energy source reliability.
As a result of these concerns, the CPUC issued an Order Instituting Rulemaking to consider revisions to Rule 20. On Feb. 13, 2020, the CPUC issued a staff proposal, which presents recommendations for changing the Rule 20 Program. The staff proposal recommends the CPUC sunset the existing Rule 20A over a 10-year period. Such a change would alter the way work credits are allocated to cities, and the way cities use work credits to fund undergrounding projects.
The League’s finalized comments addressed specific questions posed by the CPUC in their Staff proposal. In addition to addressing these questions, the League urged the CPUC to not sunset the Rule 20A Program, highlighting the various benefits of undergrounding projects and advocating for the program to be fully funded. The League also supported the CPUC’s proposal to include wildfire mitigation as an eligible criteria for Rule 20A work credits to further the recently adopted League policy, which provides, “the League supports the inclusion of wildfire mitigation as an eligible project to receive the California Public Utilities’ Rule 20 funds and efforts to expand funding for Rule 20.”
The League will provide more updates on additional opportunities to comment that may arise on this issue. In the meantime, proceeding documents are available on the Docket Card.
If you have any questions, please feel free to reach out to the League’s Deputy General Counsel Alison Leary, or Legislative Representative Derek Dolfie.

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