2. Background

The facts are not in dispute. A home builder, Barratt American, Inc., was required to convert existing overhead electric facilities to underground facilities in a new development in Rancho Cucamonga, California. In performing the work, Southern California Edison Company (SCE) included a pole removal cost of $33,700 in its charge to Barratt American. Pole removal costs in similar projects in the past have been borne by SCE.

The undergrounding work is governed by SCE's Tariff Rule 20, entitled "Replacement of Overhead With Underground Electric Facilities."

SCE acknowledges that for 30 years, from approximately 1967 to 1997, it did not include pole removal costs as part of its Rule 20 charges. However, SCE states that in 1997 it "reviewed its practices with respect to Rule 20 and concluded that pole removal costs are part of the conversion project" and therefore should be paid by the applicant.