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# Intervenors Zero In on SoCalGas's Gas-Transition Bet in 2028 Rate Case
- URL: https://www.calregulatory.com/intervenors-zero-in-on-socalgass-gas-transition-bet-in-2028-rate-case/
- Published: 2026-07-22T12:30:31.000Z
- Updated: 2026-07-22T12:30:31.000Z
- Author: MC
- Tags: Smart Meter 2.0, Southern California Generation Coalition, Indicated Shippers, Assembly Bill 2666, Mussey Grade Road Alliance, Protect Our Communities Foundation

SoCalGas/SDG&E's Test Year 2028 rate cases drew 11 protests and six responses on July 20, hitting SoCalGas on two levels: 

- Whether its year-to-year spending and recovery mechanisms are justified; and
- How much long-lived gas infrastructure customers should finance as gas use declines.

SoCalGas seeks **$5.1 billion** for 2028, up **$485 million**, or **10.5%**, from what it expects to collect in 2027, with further increases through 2031\. SDG&E seeks **$3.8** billion, up **8.1%**.

Those single-digit figures rest on a friendly baseline. Measured against 2024 (the last rates the Commission actually set) SoCalGas's request runs about **34%** higher and SDG&E's about **41%**. The Indicated Shippers reach the same point another way: against the **$4.232 billion** first authorized for 2027, SoCalGas's ask is up **20.5%**. 

By CRI's math, the four-year jump from 2024 comes to approximately **$1.3 billion** for SoCalGas. Its percentage trails SDG&E's, but it asks for more dollars, and it is gas-only, with no electric business to gain load as customers electrify.

Cal Advocates [wants to make the case bigger](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M611/K588/611588384.PDF?ref=calregulatory.com). It asks the Commission to fold three separate proceedings into the General Rate Case: 

- SoCalGas's **$3.76 billion** advanced-metering project;
- SDG&E's **$825 million** Smart Meter 2.0 proposal; and
- The utilities' **$348.1 million** SAP software migration.

Metering, billing and core software are basic utility functions, it argues, so those items belong in the budget review, and one combined case would show customers the full bill instead of splitting it across four dockets. 

---

### **Intervenors Go After SoCalGas's Forecasts and Accounting** 

The Southern California Generation Coalition (SCGC), which represents power generators that buy gas transportation from SoCalGas, [says](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M611/K619/611619393.PDF?ref=calregulatory.com) O&M costs across gas engineering, transmission and storage would climb about **21%** between 2025 and the 2028 forecast. It will press for cuts. 

Additionally, SCGC opposes the automatic annual increases SoCalGas wants for 2029 through 2031 (**6.19%**, **5.77%** and **5.49%**), set by outside cost indexes rather than shown need. It argues the Commission could hold the prior **3%** cap, or grant no increase at all. 

SCGC also finds a contradiction: SoCalGas would close six cost-tracking accounts on the theory that those costs are now predictable. Yet at the same time, it would reopen its transmission-integrity account to two-way treatment, which lets it recover overruns from customers rather than absorb them. It never explains why transmission-integrity costs are less predictable than the six it is closing.

The Indicated Shippers [cite](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M611/K970/611970569.PDF?ref=calregulatory.com) two safety programs that cost more than they save: 

- A **$1.25 billion** pipe-replacement effort called DREAMS, which only clears a benefit-cost test under a discount rate that favors long-term social benefits; and
- **$84 million** for meter protection, which returns about a penny per dollar spent.

State safety regulators have already found the underlying pipe-risk model soft — SoCalGas can redraw the boundaries of a pipe "location" and change its risk score, weakening the very threshold meant to decide what gets replaced. The Shippers also want the CPUC to strip out SoCalGas's earnings-sharing plan, which would have customers cover part of any earnings shortfall while splitting the upside. The Shippers say that shifts shareholder risk onto ratepayers and belongs in a separate cost-of-capital case, where the Commission rejected the same idea in 2012.

### Assembly Bill 2666 Makes the CPUC Check Forecasts Against Actual Costs

TURN [cites](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M611/K644/611644331.PDF?ref=calregulatory.com) possible noncompliance with the CPUC's [March 2026 RAMP ruling](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M601/K687/601687348.PDF?ref=calregulatory.com) and [Assembly Bill 1167](https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill%5Fid=202320240AB1167&ref=calregulatory.com) limits on ratepayer-funded lobbying and advertising. [AB 2666](https://calmatters.digitaldemocracy.org/bills/ca%5F202320240ab2666?ref=calregulatory.com) reaches further. It requires the Commission to compare prior forecasts with recorded costs and adjust the next revenue requirement. Protect Our Communities Foundation (PCF) [says](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M611/K644/611644339.PDF?ref=calregulatory.com) Sempra hasn't supplied those comparisons or the actual-return data the last GRC required. TURN raises the same question. 

### **Protect Our Communities Foundation and Mussey Grade Road Alliance Target SDG&E's Capital and Wildfire Plans**

PCF argues the rate-base model favors utility-owned infrastructure over cheaper customer-sited options, and attacks SDG&E's **8.7%** 2029 increase, its **$232 million** undergrounding exception and a **$1.19 billion** grid-hardening program. Mussey Grade Road Alliance [disputes](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M611/K619/611619375.PDF?ref=calregulatory.com) SDG&E's risk-scaling function and its use of non-reportable "evidence of heat" events, which it says distort ignition probabilities and understate covered conductor's value.

### **The CCAs Contest How SDG&E Allocates Costs**

San Diego Community Power and Clean Energy Alliance [ask](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M611/K617/611617965.PDF?ref=calregulatory.com) whether SDG&E assigns costs correctly among generation, distribution and other functions. Moving generation expense into distribution, they warn, would make CCA customers subsidize bundled service and let SDG&E hold down its apparent generation rates. 

### **The California Environmental Justice Alliance and Climate Action Campaign Question Gas Investment as Demand Falls**

These parties ask whether pipelines assigned 70-year lives can be justified on a three-year meter forecast that the Climate Action Campaign (CAC) [says](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M611/K619/611619399.PDF?ref=calregulatory.com) ignores falling use per customer. Both groups warn that early retirement, decommissioning and stranded-cost risk would hit a shrinking customer base that is least able to electrify. The California Environmental Justice Alliance also [challenges](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M611/K970/611970568.PDF?ref=calregulatory.com) funding for biomethane, CNG fueling, gas vehicles and advocacy costs it says AB 1167 may bar.

### **Instant Analysis**

Three baselines are in play, and the Commission's choice among them sets the stakes. SoCalGas's request is **10.5%** above its updated 2027 estimate, **20.5%** above the amount first authorized for 2027, and about **34%** above the 2024 test year. The Commission can measure the request against any of the three. Which one it picks sets what SoCalGas has to defend: a 10.5% increase over last year's figure, or $1.3 billion of growth built up since 2024.

The strongest protests go past single line items. 

- SCGC targets SoCalGas's O&M forecasts and attrition indexes;
- The Indicated Shippers hit sub-1.0-Benefit-Cost Ratio pipe spending, the balancing-account reversal and earnings sharing;
- TURN and Cal Advocates challenge recorded costs, actual returns and RAMP compliance.

Together, these intervenors ask whether SoCalGas uses forecasts and recovery tools to treat growth as the default even as its customer base shrinks. AB 2666 helps them: it makes the Commission check the last cycle's forecasts against what SoCalGas actually spent before it approves new rates.

If the Commission grants Cal Advocates' consolidation request, the whole case changes shape. The CPUC would judge SoCalGas's request against a combined bill of nearly **$10 billion**, not the $5.1 billion GRC alone, and decide how much aging pipe and new technology customers can fund at once while gas demand falls.