Cost-Recovery Battle Begins for SB 1221: Rate Base, Regulatory Assets, or No Recovery at All?

EXECUTIVE SUMMARY

Senate Bill 1221 has moved into a cost-recovery decision: whether pilots are treated as infrastructure or customer programs. Utilities are seeking near-parity with traditional gas investment economics, while other parties are trying to limit recovery or confine costs to participating customers.

The CPUC's handling of this matter will determine whether pilots scale as a system-level transition tool or remain targeted, customer-funded projects.