December 4, 2025 CPUC Voting Meeting Results
On December 4, the CPUC's business meeting agenda included attempts to impose methodological discipline on expensive capital programs even as procurement costs surge beyond forecast:
- Resolution SPD-37 deliberately slows undergrounding deployment to tighten cost-benefit standards;
- Diablo Canyon's $382 million revenue requirement prompts procedural discomfort despite statutory compliance; and
- SDG&E's 2026 procurement revenue requirement jumps from $122 million to $824 million, driven almost entirely by volatile market benchmarks.
Meanwhile, the Commission is executing a controlled shutdown of ratepayer-funded clean-energy incentive programs while politically preserving underperforming assets like Ivanpah, whose economics remain weak but whose megawatts are too valuable for the Commission to relinquish (it seems).
Three significant items were delayed to December 18 (including tariff on-bill financing and BioMAT extension decisions) suggesting commissioners need additional time to reconcile cost-containment goals with decarbonization mandates and stakeholder pressure.
Undergrounding of Electrical Equipment
Resolution SPD-37 updates the CPUC’s Senate Bill 884 undergrounding program by expanding and tightening review, cost-justification, and audit requirements. These requirements were established under Resolution SPD-15 and aligned with Energy Safety’s 2025 guidelines for 10-year Electric Undergrounding Plans.
The resolution standardizes:
- Project data submissions;
- Revenue-requirement models; and
- Decision-making metrics.
The resolution also requires utilities to justify work outside high-fire-threat areas and limits eligibility to projects with benefit-cost ratios of at least 1 that meet defined risk thresholds. Additionally, Draft Resolution SPD-37 conditions cost recovery on:
- Outperforming alternative mitigations;
- Adhering to approved cost and benefit limits; and
- Meeting Energy Safety performance standards...
...while introducing annual Electric Undergrounding Plan audits and a cumulative memorandum-account cap to guard against uncontrolled cost transfers.
Commissioner Remarks from the Dais
Commissioner John Reynolds added the following remarks prior to the resolution carrying 5-0.
...the hard truth is that the only way out is through. There are investments we need to make. There is physical risk reduction today to reduce the risks of catastrophic costs tomorrow. Delay ultimately doesn't save money, it just shifts the risk forward. Because the stakes are so high, we spent years working on how to mitigate wildfire risk strategically and cost effectively. Many proceedings tackle these issues, including General Rate Cases, wildfire and catastrophic event applications, and this resolution. And the Risk-Based Decision-Making rulemaking (or RDF) also set new rules for how utilities measure, report and plan risk mitigation. I was honored to lead that proceeding, and that we've come to develop this risk-based policy. In building that framework, we've been guided by a fundamental principle: utilities need to make smart decisions with customer dollars to mitigate risk. Ultimately, it's the utility that has to operationalize the policy and funding levels we set.
...some may wonder: 'Why add another step to an already compressed timeline?' and I'll be direct about the reasoning – the costs here are enormous. We are potentially going to be evaluating 10 or 11 figures in capital costs with average monthly customer bill impacts estimated as high as $25.
With stakes that high for a single capital program, we need to get the methodology right. There are multiple methods for reducing wildfire risk, and no party thinks we should underground the entire electric grid. Yet we need further refinement of our funding standard to evaluate which projects justify ratepayer funding, the policy goals haven't changed. We want utilities to make smart, cost effective decisions that genuinely reduce wildfire risk, but the specific metrics and thresholds that will govern billions of dollars in spending deserved for our development with full stakeholder input.