In Sarale v. Pacific Gas & Electric Co. (2010) 189 Cal.App.4th 225, the plaintiff landowners brought an action against the utility alleging the utility engaged in excessive trimming of commercially productive walnut trees located under the utility's power lines, and the trial court sustained the utility's demurrers without leave to amend and dismissed the complaints under section 1759. (Sarale, at p. 230.) A divided court concluded that because the PUC had undertaken to study tree clearances around overhead power lines, and had thereafter adopted statewide standards for minimum tree clearances while also recognizing that "'vegetation management practices may make it advantageous to obtain greater clearances than those listed'" (id. at p. 239), the second part of the Covalt test had been satisfied because "it is quite apparent that the commission has exercised its jurisdiction to regulate tree trimming around power lines." (Sarale, at p. 239.) The Sarale majority concluded that, for purposes of evaluating whether a lawsuit seeking to challenge tree trimming beyond the minimum clearances was precluded by section 1759, the second part of the Covalt test had been satisfied, reasoning "it does not matter whether we characterize the commission's actions broadly, as addressing 'the management of vegetation near power lines,' or narrowly, as addressing 'minimum tree trimming clearances.' What matters is that the commission has exercised its authority to adopt a regulatory policy relating to tree trimming around power lines--regardless of how that policy may be characterized." (Ibid.)