Rule 20

What is Rule 20?

Rule 20 is the tariff that governs utility undergrounding of overhead wires at the request of third parties (e.g., local governments, businesses, and residential customers). The Rule 20 program is currently split into three subdivisions in the tariff based on how much funding ratepayers contribute to the project (Rule 20A, Rule 20B, and Rule 20C). The table below shows the breakdown of the percentages of contributions for each tariff subdivision:

Because ratepayers contribute most if not all the costs of Rule 20A programs through utility rates, the projects must be in the public interest, meaning they must meet one or more of the following criteria:

• Eliminate an unusually heavy concentration of overhead lines; 
• Involve a street or road with a high volume of public traffic; 
• Benefit a civic or public recreation area or area of unusual scenic interest; 
• Be listed as an arterial street or major collector as defined in the Governor’s Office of Planning and Research (OPR) Guidelines. 

“General public interest” under these criteria is determined by the local government after holding public hearings and in consultation with the utilities.

Historically, Rule 20A has allowed utilities to annually allocate funds defined as work credit to communities, either cities or unincorporated areas of counties, to convert overhead electric facilities to underground. Work credits act as a sort of voucher or non-monetary dollars assigned to a local government, which the local government can redeem to perform undergrounding projects in consultation with the serving utility on a one work credit-to-one dollar basis. The utility then recovers the cost of the completed project through rates.

Rule 20B and 20C projects are not fully ratepayer funded, and hence do not need to meet the above public interest criteria to be performed. Applicants work in consultation with the serving utility to perform this work.

Per CPUC Decision (D.) 23-06-008, work credits issued in this program are to be deemed expired at the end of 2033, meaning that after that time they cannot be redeemed to perform undergrounding work. Additionally, this Decision requires the utilities to reallocate work credits from inactive communities to active Rule 20A projects with the following prioritization criteria:

• Projects with insufficient work credits in city, unincorporated county, or tribal jurisdiction with incomplete projects since 2004; or,
• Where active Rule 20A Projects have at least 50% of the main trench line within an Environmental and Social Justice (ESJ) Census Tract, defined as a census tract that meets one of the following criteria:
• Scores in the top 25 percent of CalEnviroScreen 4.0, along with those that score within the highest 5 percent of CalEnviroScreen 4.0's Pollution Burden but do not receive an overall CalEnviroScreen score; or,
• Is located in any federally recognized Tribal lands; or,
• Aggregated household income is less than 80 percent of area or state median income.

Finally, D.23-06-008 also required and instituted the following:

• PG&E, SCE, and SDG&E’s Semi-Annual Local/Tribal Workshop agendas, previously required by D.20-06-017, must also include a briefing about the utility’s wildfire-related transmission and distribution investment plans, including plans for potential undergrounding project locations that are not final; and an opportunity for local and tribal governments to share their priority sites for wildfire-related undergrounding projects.
• Discontinue the Rule 20D program, which allocated ratepayer-funded work credits to projects for mitigating fire risk exclusively in SDG&E’s territory (no projects were performed).

How can I take advantage of the Rule 20 program?

To learn more about the Rule 20 program and how to apply for a Rule 20 project, applicants should familiarize themselves with the Rule 20 Guidebook in their utility territory. The guidebooks include all information needed to initiate a Rule 20 A/B/C project, including estimated timelines, detailed guidance on the application process, and utility contact information (among other things). As a note, Bear Valley Electric Service was exempted from the requirement to create this guidebook by D.21-06-013.

Utility guidebook links are found below:

• Pacific Gas and Electric
• San Diego Gas & Electric
• Southern California Edison
• Liberty Utilities
• PacifiCorp

Utility contact information and Rule 20 webpages can be found in the links in the sidebar.

Other Utility Undergrounding Initiatives

The Investor-Owned Utilities (IOUs) also perform undergrounding in other programs for other purposes, chief among which is for wildfire mitigation. Currently, utilities detail undergrounding for this purpose in their Wildfire Mitigation Plans (WMPs), which are adopted by the Office of Energy Infrastructure Safety, ratified by CPUC, and implemented by the individual utilities. With the focus on utility-caused wildfires and the recent passage of Senate Bill 884 (McGuire), planned undergrounding activity has grown to be a large part of utilities’ wildfire mitigation strategies. To learn more about these plans and process, visit the links below:

• Investor-Owned Utility Wildfire Mitigation Plans and Recommendations to Energy Safety | Office of Energy Infrastructure Safety (ca.gov)
• Electrical Undergrounding Division – SB 884 | Office of Energy Infrastructure Safety
• Each utility also provides information on various webpages related to wildfire undergrounding and Wildfire Mitigation Plans: PG&E, SCE, SDG&E, BVES, PacifiCorp,and Liberty.

The Public Utilities Code also includes a section on undergrounding for scenic highway beautification (PU Code 320). Projects are initiated by utilities, often with the support of the California Department of Transportation (CalTrans) for this purpose and are submitted by Advice Letter to the CPUC for approval. These projects are not common. For more information, see the presentation here.

Annual Reports

In compliance with Decision (D.) 21-06-013, the IOUs are required to submit annual reports on the Rule 20 program to the CPUC. These reports include detailed information about planned, in-flight, and completed projects in tabular and geo-spatial formats. Some information has been deemed confidential, but redacted public versions of the reports can be found on the utilities’ Rule 20 websites. CPUC’s template for annual reporting can be found here.

Questions on Regulatory Information

For questions related to the Rule 20 Tariff and regulatory information, please email Rule20Questions@cpuc.ca.gov. For questions related to specific projects, please contact the utilities directly using the links in the sidebar.

Rule 20 Proceeding Information

More information on Rule 20 related proceedings can be found here.

The docket card for the now closed R.17-05-010 can be found here: R.17-05-010 Proceeding Details (ca.gov)

Pertinent Decisions:

• D.23-06-008: Phase 2 Decision Revising Electric Rule 20 And Establishing Local and Tribal Government Consultation Requirements

• D.21-06-013: Phase 1 Decision Revision Electric Rule 20 And Enhancing Program Oversight.