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).
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- 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.
Low-Income Subsidies
SCE filed an application seeking CPUC approval of its Energy Savings Assistance, California Alternate Rates for Energy, and Family Electric Rate Assistance programs and budgets for the 2028–2033 cycle. The application requests $781.8 million in total cost recovery, including $674.5 million for ESA delivery and $107.3 million for CARE and FERA administration.
SCE proposes to serve nearly 387,000 homes, targeting 195.4 GWh in cycle savings versus 131.5 GWh in the prior cycle, maintain a 92% CARE participation rate, and increase FERA participation to 30% by 2033. The proposal folds building electrification and expanded HVAC offerings into the ESA program while closing the Southern Multifamily Whole Building program and transitioning that delivery to ESA as well.
SCE estimates the request would increase system average rates by about 0.12%, or $0.14–$0.22 per month for a typical residential customer. Cost recovery would continue through existing balancing account mechanisms. (We summarized PG&E's equivalent filing here.)
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INSTANT ANALYSIS: This application sets the baseline for the 2028–2033 income-qualified program cycle and will likely be absorbed into a consolidated IOU proceeding. Nearly $0.8 billion is proposed for ESA, CARE, and FERA, with modest systemwide rate impacts. The main move is consolidating electrification and expanded HVAC measures into ESA while winding down pilots and regional programs, even as cost-effectiveness falls below Commission targets. SCE emphasizes affordability, arguing that higher administrative spending and upfront eligibility checks will reduce subsidy leakage over time, a claim intervenors are likely to scrutinize closely.
Undergrounding
Cal Advocates, TURN, and the Mussey Grade Road Alliance filed a joint application for rehearing challenging Resolution SPD-37, which revised the CPUC’s Senate Bill 884 undergrounding framework. The parties argue the Commission committed legal error by creating an expedited “Phase 1 Application” process without defining party status, shortening response timelines to 15 days, and eliminating meaningful discovery and hearings. They contend these procedural defects violate the CPUC’s own rules and deny due process in decisions that will shape future undergrounding cost recovery.
For context, see our summary of Resolution SPD-37 here.
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INSTANT ANALYSIS: This application is about procedural control rather than undergrounding policy itself. The joint parties are pushing back on the CPUC’s use of a resolution to impose an accelerated, quasi-adjudicatory process that could shape billions in future cost recovery without formal party status, discovery, or hearings. If granted, rehearing would slow SB 884 implementation but reinforce firm limits on how far the Commission can go in setting cost, audit, and oversight rules outside a standard application proceeding.
SoCalGas's Safety Culture
SoCalGas filed its 2025 Q4 Safety Culture Improvement Plan Quarterly Report in I.19-06-014, detailing progress on implementing its revised safety culture framework approved in a 2023 decision (D.23-12-034).
The report describes companywide efforts during October–December 2025 to embed safety as a shared value rather than a narrow compliance function, structured around four plan elements. Key activities included executive and director safety culture coaching (68 leaders total), expanded leadership field engagement through 87 “Live-a-Day” visits, rollout of enhanced supervisor onboarding and leadership training programs, pilot implementation of structured Tailgate Safety Briefings, and near-completion of a new Safety Manual for Employees shaped through frontline co-creation.
SoCalGas also advanced governance changes to its Safety Management System (SMS), completed an SMS Policy (August 2025) and SMS Manual (December 2025), and began integrating revised plan actions into ongoing Plan-Do-Check-Act review cycles. The filing reports $5.9 million in cumulative program costs to date, outlines lessons learned and implementation challenges, and identifies planned refinements and additional activities for 2026, including expanded learning teams, clearer metrics, and deeper employee feedback mechanisms to support sustained cultural change.
INSTANT ANALYSIS: SoCalGas is demonstrating procedural compliance with D.23-12-034 by documenting steady implementation of its revised Safety Culture Improvement Plan using a Plan-Do-Check-Act framework, with heavy emphasis on leadership training, internal communications, and Safety Management System governance rather than operational rule changes. The report reads as a maturity and accountability exercise aimed at the Safety Policy Division (showing activity, metrics, and feedback loops) while deferring any substantive safety outcome evidence to future quarters.
Natural Gas Storage
Brookfield Infrastructure Fund GP II, Rockpoint Gas Storage Inc., Wild Goose Storage, LLC, and Lodi Gas Storage, L.L.C. filed a joint application under Public Utilities Code §854.
- The request asks 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. Rockpoint Gas Storage Inc. already holds a 40% interest in the operating companies through that IPO; this application seeks authorization for Rockpoint Gas Storage Inc. to acquire Brookfield's remaining 60% interest, with the change of control occurring when RGSI crosses 50%.
- The end state would be widely held public ownership, with no single controlling shareholder. A 12-month standstill from the October 15, 2025 IPO means the earliest transaction date would be October 15, 2026, aligned with the applicants' proposed September 2026 decision timeline.
- The applicants state the transaction will not change operations, management, staffing, tariffs, or safety practices. Rockpoint would continue day-to-day oversight, and all existing CPCN conditions and CPUC jurisdiction would remain in place. They argue the transaction is not adverse to the public interest because it preserves reliability and competition while improving transparency and access to capital.
- The filing explicitly states that A.25-12-004 (the pending revolving credit facility refinancing application involving Wild Goose and Lodi asset pledges) is "not interrelated" and "should not be consolidated" with this proceeding.
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INSTANT ANALYSIS: While presented as a governance and capital markets transaction, this application directly implicates system-critical storage assets that support Northern California reliability during peak conditions. The applicants emphasize no change to operations, management, safety practices, tariffs, or CPUC oversight, which will frame the Commission's review and future enforcement posture. For CRI readers, this matters because §854 approvals often become durable precedent for how gas storage ownership, financing, and control can evolve as California navigates long-term gas planning, reliability risk, and capital access constraints.