BILL ANALYSIS                                                                                                                                                                                                              1
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                SENATE ENERGY, UTILITIES AND COMMUNICATIONS COMMITTEE
                               DEBRA BOWEN, CHAIRWOMAN
          

          SB 1511 -  Morrow                                 Hearing Date:   
          April 23, 2002             S
          As Introduced:  February 20, 2002       FISCAL           B

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                                      DESCRIPTION
           
           Current law  provides a process for the undergrounding of  
          overhead electric lines.  Generally, ratepayer money is used to  
          underground lines that are identified by local governments  
          according to rules specified by  the California Public Utilities  
          Commission (CPUC).  Current regulations require that only the  
          public utility can perform the undergrounding, though utilities  
          have the option of contracting out some functions of a job as  
          workload dictates.

           This bill  allows competitive bidding for the undergrounding work  
          by allowing cities and counties to select bids from either the  
          utility or other non-regulated contractors to design or install  
          the underground facilities.  

           This bill  requires the utility to provide a cost-based bid which  
          the city or county can then take to competitors to see if they  
          can beat that price.  If the selected bidder is the  
          non-regulated contractor, the amount that is added to the  
          ratebase is the lower of the utility's bid or the verified  
          actual cost.  The utility shall initially inspect the work of  
          the non-regulated contractor without charge.

           Amendments  . The author will offer amendments in committee to  
          delete Section 2 of the bill, from Page 4, Line 5 through Page  
          7, Line 7, and make relevant changes to the intent language on  
          Page 2.  Those sections of the bill are therefore not analyzed.

                                      BACKGROUND











           
          Rule 20 of the electric utility tariffs governs the replacement  
          of overhead electric lines with underground facilities.  The  
          CPUC allows the utilities in the aggregate to spend about $150  
          million annually on undergrounding, which is all recoverable  
          from ratepayers.  This money doesn't go far, since the cost of  
          undergrounding is reportedly as much as $1 million per mile.

          There are several types of Rule 20 undergroundings, the most  
          common of which is the Rule 20A undergrounding.  Under this  
          rule, each utility allocates its share of the total $150 million  
          budget to the cities and counties it serves on a basis which is  
          generally proportionate to each entity's percentage of the  
          meters served by overhead lines.  The city or county then  
          determines where the undergrounding should occur based on a  
          public interest finding.  Rule 20 specifies that an  
          undergrounding is in the public interest if it eliminates an  
          unusually heavy concentration of overhead electric facilities,  
          the adjacent street is extensively used by the public and  
          carries a heavy volume of traffic, or the street passes through  
          a civic area or public recreation area or an area of unusual  
          scenic interest.

          Rule 20 undergroundings are complex undertakings in that they  
          require coordination of many parties and the effect of the  
          construction is very public.  Police and fire services must be  
          notified because traffic patterns are disturbed as streets are  
          dug up and street signals are displaced, businesses are  
          disrupted as electric service is interrupted in the immediate  
          area, grid coordination is required to ensure that areas outside  
          of the immediate area retain their electric service, and  
          telecommunications and cable utilities with overhead lines must  
          time their efforts with those of the electric utility.  The Rule  
          20 work is currently performed exclusively by utilities, though  
          they may subcontract some of that work as workload dictates.  

          Other types of utility installations can be performed by  
          non-utility contractors.  Since 1983, the CPUC has allowed  
          non-utility contractors to install and, later, design line  
          extensions, which are the wires, conduit, trenches, and poles  
          necessary to bring electric service from the utility facility at  
          the street to the customers electric meter on the side of his  
          house.











          Responding to concerns about utility reconstruction following  
          the fires in the Oakland hills, the Legislature passed AB 1149  
          (Aroner), Chapter 844, Statutes of 1999, to require the CPUC to  
          study ways to revise its rules governing the replacement of  
          overhead electric and communications lines with underground  
          facilities.  After public hearings, the CPUC issued a decision  
          on amending the undergrounding rules (D.01-12-009).   A second  
          phase of the proceeding was opened to explore issues needing  
          evidentiary hearings, such as whether competitive bidding of  
          undergrounding work is in the public interest.  That second  
          phase isn't expected to conclude until next year.

                                       COMMENTS
           
           1.Historical Perspective  .  Utilities have been resistant to the  
            idea of competitive bidding for Rule 20 projects, noting the  
            complexity of the work, the need for coordination, worker  
            safety issues, cost recovery issues, and the general notion  
            that building transmission and distribution lines is at the  
            core of the utility business.  Utilities are responsible for  
            the operation and maintenance of the lines, a responsibility  
            made more problematic if those lines are installed by someone  
            else.

           2.Contracting Out of Certain Utility Functions Not New  .  As  
            noted above, the precedent for allowing non-utility  
            contractors to design and build utility plant has been in  
            place since the early 1980s in the form of line extensions.   
            However, the utilities note that line extensions are much  
            smaller and simpler projects than Rule 20 undergroundings.   
            Further, Rule 20 undergroundings effect many customers, while  
            line extensions effect only the customer to which the line is  
            being extended.

           3.Short Term Savings or Long Term Costs?   The goal of the bill  
            is to reduce the costs to ratepayers by utilizing competitive  
            forces to reduce the cost of Rule 20 undergroundings.  While  
            reducing ratepayer costs is a universally shared goal, it  
            isn't clear that competition in the Rule 20 undergrounding  
            process will achieve that goal without doing harm to other  
            competing goals of safe and reliable service.  For example,  
            requiring a utility to use a contractor that the city or  
            county selects solely on the basis of cost forces the utility  
            to work with an entity that it didn't select and may never  










            have worked with before.  While there may be savings on the  
            undergrounding project, those savings will be wiped out should  
            the low bid contractor selected by the city or county damage  
            electrical lines or rupture a sewer line as it attempts to  
            coordinate its efforts with the utility and other entities  
            involved in the undergrounding project.
           
           4.The CPUC Is On The Case  .  Pursuant to AB 1149 (Aroner) of  
            1999, the CPUC is opening a proceeding specifically to address  
            the question of whether competitive bidding of undergrounding  
            work is in the public interest with a scoping memo due out in  
            May.  Given that the issue is teed up before the CPUC,  the  
            author and committee may wish to consider  whether it would be  
            preferable to let it work through the issues and render a  
            decision.  Alternatively,  the author and committee may wish to  
            consider  requiring the CPUC to consider whether and under what  
            conditions non-utility contractors should be permitted to  
            compete in Rule 20 projects, thereby assuring the CPUC  
            addresses the issue.  

                                       POSITIONS
           
           Sponsor:
           
          Author

           Support:
           
          City of Oakland
          City of San Carlos
          UDI-TETRAD Consulting Engineers, Inc.

           Oppose:
           
          Coalition of California Utility Employees
          Sempra Energy
          



















          Randy Chinn 
          SB 1511 Analysis
          Hearing Date:  April 23, 2002