WEDNESDAY AGGREGATE: SoCalGas AMI Cost Tracking; SCE Low-Income Budgets; a Challenge to Undergrounding Resolution SPD-37

Today's aggregate includes:

• Activity involving SoCalGas's AMI replacement application;
• SCE's application for CARE, ESA, and FERA budgets for the 2028–2033 cycle;
• An application for rehearing of Resolution SPD-37, which revised the CPUC’s Senate Bill 884 undergrounding framework;
• SoCalGas's 2025 Q4 Safety Culture Improvement Plan Quarterly Report; and
• A request asking to transfer indirect control of the Wild Goose and Lodi gas storage facilities from Brookfield to Rockpoint Gas Storage Inc., a publicly traded company created through an October 2025 initial public offering.

Natural Gas Advanced Metering Infrastructure

SoCalGas filed a motion asking the CPUC to authorize an interest-bearing Advanced Meter Infrastructure Replacement Memorandum Account to track costs incurred while the Commission reviews its AMI replacement application (see our summary of the application here).

New SoCalGas AMI Application

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CALIFORNIA REGULATORY INTELLIGENCE (CRI)MC

• SoCalGas argues its existing AMI system, deployed between 2012 and 2018, is approaching end-of-life, with module battery failures expected around 2030 and manufacturer support winding down, creating operational, billing, and cybersecurity risks if replacement work is delayed.
• SoCalGas says it must begin vendor selection and system pre-planning during the pendency of the case and seeks to record about $4 million in incremental costs effective December 30, 2025, the application filing date, with recovery subject to a later reasonableness review.
• SoCalGas cites Commission precedent approving similar memorandum accounts for PG&E and SDG&E AMI and billing modernization projects and emphasizes that the request does not prejudge cost recovery, but preserves neutrality for ratepayers and shareholders while the application is under review.

INSTANT ANALYSIS: This is a standard but consequential interim cost-protection move. SoCalGas is laying down a marker to begin AMI replacement work now, rather than wait for a final decision, by securing a memorandum account effective as of the application filing date. The Commission has consistently approved similar requests for PG&E and SDG&E when large, time-sensitive system replacements risk higher costs or operational failure if delayed, which strengthens SoCalGas’s position. The true battles are deferred: authorization of the memo account does not guarantee recovery, but it meaningfully reduces SoCalGas’s exposure and increases the likelihood that early AMI replacement costs will be treated as reasonable once the merits of the broader application are decided.