SoCalGas Update: Parties File Opening Briefs in TIMPBA Proceeding

On December 12, parties filed opening briefs in the proceeding where SoCalGas requests review and recovery of $173.8 million of costs recorded in its Transmission Integrity Management Program Balancing Account (TIMPBA).

SoCalGas's filing packages five years of transmission-integrity spending into a single reasonableness review, creating a serious test of whether its inspection, remediation, and project-management costs can withstand intervenor scrutiny. For industrial shippers, the outcome will determine how much of the 2019–2023 safety portfolio ultimately flows through into future transportation rates.

SoCalGas

SoCalGas defends its request by asserting that the challenged TIMP costs were driven by mandatory federal pipeline safety requirements under 49 CFR Part 192, including expanded threat identification, assessment, and remediation obligations that were not fully foreseeable in SoCalGas's Test-Year 2019 General Rate Case.

SoCalGas argues"

• Its inspections are continuous and cyclical rather than duplicative;
• That work on non-HCA segments is required for system integrity; and
• That labor, vendor, and related costs are properly attributable to TIMP activities.

SoCalGas emphasizes the extensive record it submitted (including thousands of pages of workpapers) and contends that prior Commission approvals, including Resolution G-3600, confirm the compliance-driven nature of TIMP spending. SoCalGas asks the Commission to find the costs just and reasonable, approve full recovery of the $173.8 million undercollection, and authorize a 12-month amortization period.

Cal Advocates

Cal Advocates takes a more granular approach, recommending partial denial, totaling approximately $79.0 million of SoCalGas’s requested recovery.

Cal Advocates argues that significant portions of SoCalGas's request lack evidentiary support, are non-incremental to prior GRC funding, or fall outside the scope of TIMP. Recommended disallowances include:

• Straight-time labor;
• Vacation and sick leave costs already embedded in prior revenue requirements;
• Costs associated with Pipeline 235 West that failed to comply with Commission directives; and
• Misclassified vendor expenses.

Cal Advocates recommends a reduced recovery amount consistent with documented, incremental, and properly scoped expenditures.

Indicated Shippers

The Indicated Shippers call for full denial of SoCalGas’s $173.8 million request, framing it as the second installment of an unprecedented pattern of TIMP overspending during the TY 2019 GRC cycle.

The Shippers argue that SoCalGas has exceeded authorized budgets by accelerating discretionary assessments years ahead of federal deadlines, without adequate planning, cost controls, or documentation.

The brief emphasizes the disparity between federal cost estimates and SoCalGas’s actual expenditures as evidence of inefficiency and imprudence, and warns that a 12-month recovery would impose severe rate impacts (particularly an estimated 18.7% increase in Backbone Transportation Service rates).

If any recovery is allowed, Indicated Shippers argue it should be amortized over at least 36 months to mitigate rate shock and better align with affordability and long-term gas system planning policies.

Small Business Utility Advocates (SBUA)

SBUA argues that SoCalGas has failed to meet its burden to demonstrate that the $173.8 million in TIMP costs recorded in the TIMP Balancing Account are just and reasonable.

SBUA contends the record lacks sufficient project-level justification, workpapers, and cost-effectiveness analysis, particularly for $62.3 million in inspection costs incurred within a short time frame. It argues that SoCalGas improperly front-loaded inspections despite long federal compliance timelines, failed to show that federal rule changes directly caused the cost overruns, and failed to establish that the expenditures were incremental or non-duplicative.

SBUA urges the Commission to deny the full request, require completion of a previously ordered independent TIMP study before any recovery, and direct SoCalGas to seek any future recovery through its next General Rate Case. At minimum, SBUA requests disallowances and deferral of contested costs to a future proceeding.

INSTANT ANALYSIS: This case is less about pipeline safety than about execution and cost governance. Federal compliance is not in dispute; the central question is whether SoCalGas can recover costs driven by its own decisions about timing, scope, and pace. Intervenors largely align in arguing that SoCalGas advanced inspections years ahead of federal deadlines, ran far beyond GRC-authorized budgets, and failed to clearly connect that spending to unavoidable regulatory requirements. In their eyes, the Commission is being asked to decide whether the TIMP balancing account is a safeguard for compliance uncertainty or a mechanism that absorbs aggressive program expansion after the fact.

For CRI readers, a key implication is how the Commission treats discretion inside federally driven programs. The most likely outcome is not an all-or-nothing ruling but a mix of disallowances, extended amortization, or deferral of recovery to the next GRC to allow a broader review of TIMP scope and controls. A final decision in this proceeding may set an important precedent on how the CPUC expects utilities to document incrementality, pacing, and cost discipline when safety programs exceed authorized levels.

Additional CRI coverage of this proceeding can be found here.