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Scope Approved for Audit of PG&E's Undergrounding Program

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Today we set the stage for an audit of Pacific Gas and Electric Company's (PG&E) undergrounding program (known as Rule 20A).


At our Voting Meeting the Commissioners approved an audit scope and expanded the list of objectives within the scoped items in a joint proposal by PG&E and the City of Hayward to ensure that PG&E has fully accounted for the annual Rule 20A budgeted amounts and cities will receive the full benefits of these funds.


We also determined that a competitive solicitation process should be used to select the auditor to ensure that all stakeholders view the audit results as independent. PG&E, Hayward, and our Energy Division will collaboratively draft a Request for Proposals, which will be issued by PG&E. Our staff will review bids, select the winner, and oversee the audit.


The scope of the audit will include the following items:

  1. Ensure that PG&E has fully accounted for annual Rule 20A budgeted amounts by documenting that PG&E has properly allocated the entire budgeted amount approved in its General Rate Case decisions;
  2. Ensure that localities will receive the full benefit of these funds;
  3. Assess progress in implementing steps PG&E has taken to increase its capability to perform Rule 20A conversions;
  4. Assess PG&E's processes to verify eligibility of Rule 20A projects; and
  5. Verify the reliability of Rule 20A project cost estimates.

The cost of the audit will be absorbed within PG&E's existing budget for the program.


A Rule 20A undergrounding project is initiated by a city or county and typically occurs in areas of a community that are used by the public. Because ratepayers contribute a significant portion of the costs of Rule 20A projects through utility rates, the projects must be in the public interest by meeting 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 Guidelines.

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