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Home > News > News Articles > 2020 > March > Deadline Extended to April 21 for Cities to Provide Comments on CPUC Rule 20 Program
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Deadline Extended to April 21 for Cities to Provide Comments on CPUC Rule 20 Program

March 27, 2020
At the League’s request, the California Public Utilities Commission (CPUC) has extended the deadline to file comments on the Staff Proposal for Rule 20 Program Reform and Enhancements (Staff Proposal) to April 21, 2020. 
Administrative Law Judge Wang’s email ruling on March 25, 2020 provides that all parties have until April 21, 2020 to file and serve opening comments, and relaxes the rules to become a party to the proceeding. The email ruling, therefore, makes it easier for cities to submit comments on the staff proposal. Parties that wish to take advantage of the email ruling must reference the email ruling in the opening paragraph of their comments.
The CPUC Rule 20 Program lays out guidelines and procedures for undergrounding overhead electric facilities. This program is provided at four levels, known as Rule 20A, B, C, and D.
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 Electric Rule 20. On Feb. 13, 2020, the CPUC issued a Staff Proposal.
The staff proposal presents recommendations for changing the Rule 20 Program to resolve issues at all four levels of the program. Significantly, the staff proposal recommends the CPUC sunset the existing Rule 20A and Rule 20D programs over a 10-year period, and replace the allocation-based programs with a modified Rule 20B program or other new programs. Such a change would alter the way work credits are allocated to cities, and the way cities use work credits to fund undergrounding projects.
How to Engage
Cities can submit formal comments on the staff proposal directly to the CPUC, or reach out to League staff to provide feedback.
In the staff proposal, CPUC staff specifically requests comments on the following questions, among others: 
  • Are there ways that the CPUC can better encourage or incentivize self-taxation or surcharge programs among the cities and counties to accelerate undergrounding?
  • How should local surcharge programs interact with the Rule 20 program?
  • Is 90 calendar days enough time for cities and counties to form a workable underground utility district? Would 90 business days be more appropriate?
  • How have the communities benefitted from Rule 20A work credit trading?
  • Should the CPUC continue to allow work credit trading among the communities?
  • Are there other policies that the CPUC can implement to incentivize more efficient and less expensive project completion?
  • What are reasonable time thresholds for the project milestones? 
If your city would like to submit formal comments on the staff proposal to the CPUC, the city can either become a party to the proceeding by contacting CPUC Staff member Jessie Levine at for guidance on how to file and serve comments, or submit comments by following the instructions on the page “Providing Comments to the CPUC.” The deadline for parties to the proceeding to submit comments on the staff proposal is April 21.
If your city would like to send feedback to the League, please reach out to the League’s Deputy General Counsel, Alison Leary. The League is a party to the proceeding and will also be submitting comments on the staff proposal by the April 21 deadline.
Proceeding documents are available on the Docket Card.
Please contact Jessie Levine at for guidance on how to file and serve comments in accordance with the Commission's Rules of Practice and Procedure.
Stakeholders who do not have time to file and serve formal comments in this proceeding may choose to submit brief informal public comments online.

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