On September 13th, RCRC provided comments to the California Public Utilities Commission (CPUC) on the Rule 20 undergrounding program, which allows local governments to work with utilities to underground overhead powerlines. While Rule 20A projects are funded by ratepayers, Rule 20B and 20C projects are primarily funded by local governments. The Rule 20A program had rightly been criticized as benefiting larger urban areas at the expense of smaller and rural communities; however, it still provides an important tool for local undergrounding projects. 

The Rule 20A program has historically been used to underground power lines for aesthetic and disability access purposes, but the CPUC is considering expanding eligibility to include wildfire risk reduction and emergency-related projects.  RCRC and many other local governments have strongly supported expansion of the program; however, the CPUC voted last year to discontinue future allocations of ratepayer funds to the Rule 20A program.   

In comments to the CPUC on the future of the Rule 20A program, RCRC urged expansion and argued these Rule 20A projects, which are initiated by local governments, can complement other utility undergrounding projects, like PG&E’s 10,000-mile proposal.  In particular, RCRC noted that the Rule 20A program can provide an important safety net for locally-identified wildfire safety, resilience, and emergency projects that are not selected by the utility, but which are incredibly important from a local perspective. 

RCRC also strongly urged the CPUC to enhance engagement with local governments to inform investments in undergrounding for safety, resilience, and emergency-related purposes. RCRC noted that “Enhanced engagement with local governments can better inform both local government and utility decision-making, provide advanced notice of potential projects, and identify similar or overlapping public works projects within the undergrounding plan implementation horizon in order to reduce expenses, minimize environmental impacts, and avoid complications.”  RCRC appreciates PG&E’s efforts to form and work with an underground advisory group, upon which RCRC President and CEO Pat Blacklock sits, as it develops its 10,000-mile wildfire safety program and strongly supports further enhancements to improve coordination with local governments. 

For more information, contact RCRC Policy Advocate John Kennedy.