In San Diego Gas & Electric Co. v. Superior Court (Covalt) (1996) 13 Cal.4th 893, the Supreme Court established a three-part test for determining whether an action is barred under section 1759: (1) "whether the commission has the authority to adopt a policy" (id. at p. 923; see also id. at pp. 923-925); (2) "whether the commission has exercised that authority" (id. at p. 926; see also id. pp. 926-934); (3) "whether the present superior court action would hinder or interfere with that policy" (id. at p. 935; see also pp. 935-943). Covalt's three-part test, to some extent, begs the question: What is the relevant policy? The City argues that a "policy" is something more than a mere ruling or decision. We agree. "When the bar raised against a private damages action has been a ruling of the commission on a single matter such as its approval of a tariff or a merger, the courts have tended to hold that the action would not 'hinder' a 'policy' of the commission . . . and hence may proceed. But when the relief sought would have interfered with a broad and continuing supervisory or regulatory program of the commission, the courts have found such a hindrance and barred the action under section 1759." (Covalt, supra, 13 Cal.4th at pp. 918-919.) The Court declared the primacy of section 1759, and made clear that a private right of action under section 2106 is limited to those situations where an award would not " 'hinder or frustrate the commission's declared supervisory and regulatory policies.' " (Covalt, supra, 13 Cal.4th at pp. 917-918.) Under Covalt, the court considers: (1) whether the commission has the authority to adopt a regulatory policy; (2) whether the commission has exercised that authority; and (3) whether the superior court action would hinder or interfere with the commission's exercise of regulatory authority. (Id. at pp. 924.) The Court found the PUC's jurisdiction to be exclusive over issues involving the public health risks arising from electric and magnetic fields (EMFs) attributed to powerlines owned by regulated utilities. In Covalt, supra, 13 Cal. 4th at pages 903, 915-934, the Supreme Court determined that section 1759 barred a trial court action by neighboring property owners alleging lost value due to public fear of health-endangering EMFs created by powerlines owned and operated by a public utility. After demystifying EMFs and explaining the case's procedural history, Covalt described the PUC's broad constitutional and statutory mandates to " 'supervise and regulate every public utility in the State' " and to do "all things" necessary and convenient in the exercise of its jurisdiction, a grant of authority which is to be liberally construed. ( Covalt, supra, 13 Cal. 4th at pp. 914-915.) The court then examined section 1759's relationship to section 2106. Section 2106 provides that a public utility which violates the law or a commission order, whether by act or omission, shall be liable for "loss, damages, or injury caused thereby." It permits a court to award actual and exemplary damages in an action brought by the injured person or corporation. Covalt reaffirmed the narrow construction of section 2106 rendered by Waters v. Pacific Telephone Co. (1974) 12 Cal. 3d 1, which limited section 2106 to "situations in which an award of damages would not hinder or frustrate the commission's declared supervisory and regulatory policies." ( Id. at p. 4.) As explained by Covalt, "under the Waters rule, accordingly, an action for damages against a public utility pursuant to section 2106 is barred by section 1759 not only when an award of damages would directly contravene a specific order or decision of the commission, i.e., when it would 'reverse, correct, or annul' that order or decision, but also when an award of damages would simply have the effect of undermining a general supervisory or regulatory policy of the commission, i.e., when it would 'hinder' or 'frustrate' or 'interfere with' or 'obstruct' that policy." ( Covalt, supra, 13 Cal. 4th at p. 918.)