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PG&E Reports $4.05 Billion Above Capital Forecast in Risk-Spending Accountability Filing

PG&E filed its 2025 Risk Spending Accountability Report in three dockets: its 2023 General Rate Case (A.21-06-021), 2024 RAMP (A.24-05-008), and pending GRC (A.25-05-009). The 362-page filing compares CPUC-authorized spending against actual 2025 spending, with cumulative comparisons across 2023-2025.

The numbers are very large.

2025 expenses ran $650 million (10%) above adopted; capital ran $4.05 billion (57% ) above adopted in a single year. At the 2/3 mark of the four-year cycle, cumulative capital spending now stands $6.55 billion above the amount the CPUC authorized.

Electric Distribution drives the expense overrun ($294 million) on Major Emergency response, overhead maintenance, vegetation management, and inspections. Companywide Items overran $550 million on employee benefits and incentive compensation that PG&E argues were under-funded in the 2023 GRC. Customer & Communications was $55 million over.

Capital is dominated by three concentrations.

  • Electric Distribution capital ran $2.43 billion over on emergency work, pole replacements, overhead maintenance, and SB 410 customer connections.
  • Shared Services and IT capital ran 191% over ($1.33 billion) driven by the final purchase price for the Oakland General Office campus, the Propel program modernizing PG&E's enterprise resource planning system (SAP), and unplanned Oakland General Office physical security.
  • Power Generation capital ran 64% over on emergent and rescheduled hydro work concentrated at Fordyce, Pit 3, Spaulding, Helms, and other named facilities, partly masked by FERC license renewal delays at Drum-Spaulding and McCloud-Pit.

Gas operations moved in the opposite direction: PG&E underspent $148 million on Gas Distribution expenses and $101 million under on Gas Transmission and Storage. Meter protection moved from expense to capital, leak detection shifted activity codes, and Transmission Integrity Management Program work shifted to alternative assessment methods.

PG&E's High-Pressure Regulator replacement program received zero 2023 GRC funding but Gas Operations spent $56 million on it cycle-to-date because it was deemed important.

INSTANT ANALYSIS

The GRC envelope has decoupled from actual spending. What a GRC authorizes increasingly functions as the floor; what gets spent is determined by balancing-account flexibility. The Oakland General Office concentration is the clearest example. Ratepayers are simultaneously funding the building purchase, SAP modernization, and unplanned physical-security investments, none of which were accurately presaged by the 2023 GRC.

The High-Pressure Regulator program carries the same implication. The CPUC authorized zero funding, yet millions were spent anyway after Gas Operations deemed the work important. Power Generation overruns tell a parallel story inside the hydro fleet: aging facilities are generating emergent capital needs that are partially masked by delayed FERC license renewals.

PG&E's stance is that the 2023 GRC was underfunded across multiple categories, including employee benefits that the CPUC reduced in the last case. Every cost overrun documented here becomes evidence in the 2027 GRC that prior forecasts were insufficient.

CRI's coverage of the new RDF rulemaking:

Biomethane Cut, Hydrogen Denied, Transmission Financing
The CPUC’s April 30 voting meeting featured major moves on biomethane, hydrogen, transmission, electric rates, and risk-based decision-making.