September 16 Comments to the CPUC on Draft Resolution SPD-37, Utility Undergrounding

September 17, 2025

President Alice Reynolds
California Public Utilities Commission
505 Van Ness Ave
San Francisco, CA 94102

RE: Comments on Draft Resolution SPD-37 (SB 884 Program Guidelines)

Dear Commissioners, 

On behalf of the Marin County Board of Supervisors, we submit comments regarding Draft Resolution SPD-37. Marin County faces significant wildfire risk, as we know our geography includes steep terrain, dense vegetation, and constrained evacuation routes. As recent fire seasons have shown, wildfire risk is not confined by jurisdictional boundaries, and reducing ignition sources like utility infrastructure is a regional and statewide responsibility.

We strongly support the Legislature’s direction through Senate Bill 884 (McGuire, 2022) to expedite undergrounding of electrical distribution lines in high fire-threat areas. Undergrounding is a critical long-term tool to reduce wildfire ignition risk and improve grid reliability. At the same time, we recognize that these projects are expensive, and we appreciate the Commission’s responsibility to protect ratepayers at a time when so many Californians are concerned with the cost of living.

In Marin, very few miles of lines have been undergrounded in recent years. We are concerned that this pace leaves our communities vulnerable – and that the draft cost recovery guidelines under SPD 37 could slow this work further. We therefore respectfully urge the Commission to consider refinements to the draft guidelines to accelerate undergrounding in Tier 2 and Tier 3 High Fire Threat Districts, while ensuring project selection and cost recovery remain transparent, cost-effective, and equitable.

In addition to wildfire risk, overhead lines also mean Public Safety Power Shutoff events during high fire risk conditions; occurrences that impose costs on residents and businesses through lost productivity, spoiled goods, and service interruptions. Additionally, continuing to rely primarily on vegetation management and other temporary mitigations carries its own high costs and can only reduce, not eliminate, the risk of ignition. Undergrounding provides a permanent solution that, while expensive upfront, reduces long-term maintenance costs and delivers lasting safety and reliability.

We appreciate the Commission’s ongoing efforts to balance wildfire safety and affordability in implementing SB 884, and thank you for your consideration of these comments.

Sincerely, 

Mary Sackett, President
Marin County Board of Supervisors

CC:       Marin County Board of Supervisors
Senator Mike McGuire
Assemblymember Damon Connolly