SDG&E Backs Petition to Lift EV Infrastructure Spending Cap

SDG&E filed a response supporting a petition for modification (PFM), where multiple parties (Electrify America, the Natural Resources Defense Council, Walmart, Advanced Energy United, et al) seek to modify the CPUC's decision addressing SoCalGas/SDG&E's 2024 General Rate Case (D.24-12-074).

In their PFM, the petitioners argue that the CPUC should remove the $7.58 million funding cap imposed on the Electric Vehicle Infrastructure Memorandum Account (EVIMA) associated with Electric Rule 45. In supporting the PFM, SDG&E contends the cap was based on a misunderstanding of project status and accounting mechanics, noting that while many Rule 45 EV charging projects were in development, costs are not booked until projects are energized, making early balances appear artificially low.

SDG&E argues that capping a memorandum account is inconsistent with standard regulatory practice, conflicts with the Public Utilities Code, and prematurely constrains a legislatively mandated EV infrastructure program critical to fleet and public charging deployment.

SDG&E maintains that any substantive policy changes to Rule 45 should be addressed in a statewide transportation electrification rulemaking (not embedded in a single utility’s General Rate Case). It warns that the cap has already disrupted customers and developers, skewed data collection intended to inform future EV policy, and forced SDG&E to temporarily close Rule 45.

INSTANT ANALYSIS: This filing demonstrates how General Rate Cases are becoming a primary tool for the CPUC to place practical limits on utility-side transportation electrification, even where programs are grounded in statute. If the $7.58 million EVIMA cap remains in place, Rule 45 effectively becomes a rationed, stop-and-go program, creating uncertainty for fleet operators, charging developers, and large load customers planning medium- and heavy-duty electrification in SDG&E territory. The dispute highlights rising Commission skepticism toward uncapped memorandum accounts and a willingness to impose hard spending constraints through rate cases rather than dedicated policy rulemakings.