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BCUU Submits Comments to CPUC Re: Staff Recommendations for Rule 20 Reforms & Enhancements

The California Public Utilities Commission (CPUC) recently released a Staff Proposal for Rule 20 Program Reform and Enhancements.The proposed changes include:

  • Modify Rule 20B to Incorporate Tiered Ratepayer Contributions Commensurate with Public Benefits

  • Sunset the Rule 20A and 20D Programs as Currently Designed

  • Refine and Expand the Rule 20 Public Interest Criteria

  • Incentivize Municipal Utility Surcharge Undergrounding Programs

  • Eliminate Work Credit Trading with Limited Exceptions

  • Modify the Rule 20A Annual Completion and Allocation Reports

  • Adopt an Updated Rule 20 Guidebook

  • Improve Communications with the Communities and Publish Relevant Rule 20 Program Information, Documents, and Reports Online

  • Implement Incentives to Reduce Project Completion Timelines and Costs

if any) are required to be submitted prior to March 31, 2020 A Public Comment period followed the release of the staff recommendations.


BCUU in addition to acknowledging the CPUC staff considerable effort that went into auditing the past performance of Rule 20 projects and drafting the proposed reforms and enhancements, submitted four comments. They are summarized below:

1. The three-tiered CPUC fire maps proposed to be used for Rule 20B projects should (particularly in urban areas) be fully harmonized (on a block by block, parcel by parcel basis) with CalFire and City maps. This is particularly significant in urban high fire hazard zones such as those found in Berkeley. 2. Additional funding support should be extended to projects in fire mapped areas and also adjacent to major earthquake faults. 3. Sunsetting of Rule 20A should be accompanied by prompt completion of currently approved 20A projects and the simultaneous roll out the proposed new 20B program.  4. Provide Guidelines for 20B project formation and funding assistance with regard to "Up-front" preliminary engineering costs. Please direct comments/recommendations regarding this planned BCUU action to: info@berkeleyundergrounding.com

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