SB 1215 requires the California Public Utilities Commission to treat electrical distribution infrastructure on the utility side of the customer meter needed to support electric vehicle (EV) charging — for separately metered installations other than single‑family residences — as core utility distribution infrastructure. The bill directs each electrical corporation to obtain a tariff authorizing the utility to design and deploy that infrastructure, track certain early costs in a memorandum account, and recover the revenue requirement through periodic general rate case (GRC) proceedings.
The change shifts EV charging from a case‑by‑case authorization model to an ongoing, GRC‑funded utility function. That reduces transactional friction for multifamily installations but spreads costs across ratepayers, creates new CPUC accounting and auditing obligations, and replaces the line extension rules in use as of mid‑2020 with a full‑useful‑life customer allowance approach.
The bill also codifies the CPUC’s prior “common treatment” policy for excess home charging upgrade costs to be recovered from all residential ratepayers.
At a Glance
What It Does
SB 1215 directs utilities to treat utility‑side EV charging distribution work as standard distribution infrastructure and to recover costs through GRCs. It requires an advice‑letter tariff to authorize utility design and deployment for separately metered multifamily charging and mandates memorandum‑account tracking of pre‑implementation costs for later recovery.
Who It Affects
Multifamily property owners and tenants seeking separately metered EV charging, electrical corporations operating in California, EV charging infrastructure developers and installers, and residential ratepayers who may fund cost recovery through GRC outcomes.
Why It Matters
The bill changes project approval and cost allocation practice: it removes case‑by‑case CPUC approvals for utility‑side work and establishes a predictable recovery pathway. That can speed multifamily EV charging deployment but raises cross‑subsidy and regulatory‑oversight issues that compliance officers, utilities, and housing stakeholders must manage.
More articles like this one.
A weekly email with all the latest developments on this topic.
What This Bill Actually Does
SB 1215 recasts the electrical distribution infrastructure that utilities place on the utility side of the customer meter to support EV charging as the same kind of distribution work the CPUC already treats as part of a utility’s core business. Practically, that means utilities will no longer rely on individualized authorizations for each multifamily EV charging deployment; instead, the CPUC will authorize the design, engineering, and construction work through tariffs and recover the associated costs in the utility’s regular rate proceedings.
The bill directs each electrical corporation to file an advice letter (with specific filing and approval dates stated in the text) that creates a tariff allowing the utility to design and deploy such infrastructure for separately metered charging stations other than those at single‑family residences. Costs incurred between a stated historical date and the implementation date of rates approved in the next GRC are to be tracked in a memorandum account and are eligible for recovery in that subsequent GRC subject to a reasonableness review — a mechanism that effectively preserves a path for retrospective cost recovery.SB 1215 replaces the line extension rules in use as of July 1, 2020 with a regime that bases any customer allowances on the full useful life of the installed electrical distribution infrastructure.
The bill also codifies definitions (for example, what counts as electrical distribution infrastructure and what qualifies as “basic charging arrangements”) and incorporates the CPUC’s prior decisions on common treatment for excess home‑charging upgrade costs, making explicit that residential service upgrades that exceed Rule 15/16 allowances can be treated as a common facility cost recovered from all residential ratepayers.Finally, the bill instructs the CPUC to continue requiring electrical corporations to provide accurate accounting of expenses tied to these programs and to apply penalties where utilities fail to track costs properly. It also preserves the commission’s ability to revisit the policy after a utility completes the next general rate case cycle if adjustments are necessary to preserve just and reasonable rates.
The Five Things You Need to Know
SB 1215 requires each electrical corporation to file an advice letter (deadline text: not later than February 28, 2021) and obtain CPUC approval (deadline text: not later than June 30, 2021) for a tariff that authorizes utility deployment of utility‑side distribution work for separately metered EV charging, excluding single‑family residences.
Costs incurred between January 1, 2021 and the implementation date of approved rates are to be tracked in a memorandum account and may be recovered, subject to a reasonableness review, in the electrical corporation’s next general rate case revenue requirement decision.
The bill replaces the line extension rules in use as of July 1, 2020 and requires any customer allowances to be based on the full useful life of the electrical distribution infrastructure rather than shorter, project‑specific amortizations.
SB 1215 defines “electrical distribution infrastructure” broadly to include poles, vaults, service drops, transformers, mounting pads, trenching, conduit, wire, cable, meters, other necessary equipment, and associated engineering and civil construction work.
The bill codifies the CPUC’s interim “common treatment” policy by allowing residential service facility upgrade costs for home‑based basic charging arrangements that exceed Rule 15/16 allowances to be treated as a common facility cost recoverable from all residential ratepayers.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Reclassifies utility‑side EV charging work as core distribution business
This section states the bill’s core policy shift: the CPUC should stop treating utility‑side distribution infrastructure for EV charging as an ad hoc, lower‑priority activity and instead regard it as distribution work comparable to other network investments approved through GRCs. For practitioners, that means project authorization shifts from individualized CPUC approvals toward tariffed, ongoing utility functions — changing both operational workflows and the regulatory docket where disputes are likely to land.
Defines electrical distribution infrastructure
This provision provides a working list of the physical components the bill covers — from poles and transformers to trenching, conduit, meters, and associated engineering and civil construction. The list is operationally useful: it signals which assets the utility can include in tariffed programs and in customer allowances, and it narrows (but does not eliminate) ambiguity about the boundary between utility obligations and customer‑side equipment.
Tariff filing, memorandum account, and recovery through GRC
Subdivision (c) lays out the administrative mechanics: utilities must file an advice letter to establish a tariff authorizing design and deployment for separately metered multifamily charging; costs incurred from a specified past date until approved rates take effect go into a memorandum account; and ultimate recovery occurs in the next GRC after a reasonableness review. The section also instructs the CPUC to replace legacy line extension rules and to set customer allowances using full useful life assumptions — affecting capitalization, depreciation, and customer‑contribution calculations.
Key definitions and reference to prior CPUC decisions
This subsection imports operational definitions such as “basic charging arrangements” (Level 1 and Level 2 per SAE J1772) and references prior CPUC decisions and rulemakings that shaped EV policy. By anchoring the bill to existing decisions (D.11‑07‑029, D.13‑06‑014, D.16‑06‑011, D.16‑11‑005, and R.18‑12‑006), it clarifies legislative intent to align statutory treatment with the commission’s prior interim policies and to enable continuity in implementation.
Common treatment for excess residential upgrade costs
This clause authorizes the CPUC to treat residential service facility upgrade costs that exceed Rule 15/16 allowances — when those upgrades are driven by home EV charging for basic arrangements — as a common facility cost to be recovered from all residential ratepayers. That provides a mechanism to socialize certain upgrade costs that would otherwise be borne by individual homeowners or developers.
Legislative intent to preserve CPUC interim policy, with review trigger
The bill states explicit legislative intent that the CPUC’s interim common‑treatment policy (as reflected in the listed decisions and rulings) shall govern and may be revised only after the utility completes the GRC cycle in effect on January 1, 2021. This both enshrines the interim approach into statute and creates a built‑in review point tied to GRC cycles, giving the CPUC a controlled opportunity to adjust the policy if rate outcomes require it.
This bill is one of many.
Codify tracks hundreds of bills on Energy across all five countries.
Explore Energy in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Multifamily property owners who want separately metered EV charging: they gain a predictable utility pathway to have the utility design and build the distribution infrastructure on the utility side, reducing upfront capital and coordination burdens.
- Tenants and residents in multifamily buildings seeking EV charging: lowering the procedural barrier to deploy charging increases access options where on‑site charging is otherwise difficult to arrange.
- EV charging network developers and electricians: shifting work to utility‑authorized, tariffed programs creates clearer scopes of work and may increase project volume for installers who partner with utilities or perform customer‑side work to coordinate with utility deployments.
- Electrical corporations: utilities obtain an established recovery mechanism through GRCs, reducing the need for repeated case‑by‑case CPUC approvals and creating regulatory clarity about cost inclusion in distribution investments.
Who Bears the Cost
- All residential ratepayers: the bill authorizes recovery of certain upgrade costs as common facility costs from the residential class, meaning households without EVs may fund a portion of multifamily and residential EV infrastructure.
- Electrical corporations (administrative burden): utilities must track expenses precisely, file advice letters and tariffs, maintain memorandum accounts, and expose costs to reasonableness reviews—adding compliance, accounting, and reporting workloads.
- Ratepayer advocacy groups and intervenors: they bear litigation and administrative costs in GRC proceedings and reasonableness reviews when contesting recoverability, prudence, or allocation of these EV‑related costs.
- Owners of single‑family residences seeking specialized programs: because the bill excludes single‑family residences from the tariffed utility deployment pathway, those homeowners may continue to face different (potentially narrower) options and incentives.
Key Issues
The Core Tension
The bill forces a tradeoff between accelerating multifamily EV charging by embedding utility deployment and cost recovery into normal rate practice, and protecting ratepayer fairness by avoiding broad cross‑subsidies. Speed and scale favor treating utility‑side work as core infrastructure; cost‑allocation fairness and targeted incentives favor keeping costs targeted to beneficiaries.
SB 1215 resolves a procedural bottleneck by moving utility‑side EV charging work into the GRC mechanism, but that resolution creates several practical and policy tradeoffs. First, the explicit authorization for retrospective cost tracking (costs back to January 1, 2021) invites disputes over what was reasonably incurred, how costs are allocated across projects, and whether memorandum‑account entries reflect programmatic versus discretionary spending — all of which will show up in contentious GRC reasonableness reviews.
Second, the bill’s instruction to replace existing line extension rules and to set customer allowances on a full useful‑life basis changes the economics of who pays and when. That can lower upfront customer bills but increases the amount socialized across ratepayers and affects depreciation schedules and rate design.
The resulting cross‑subsidy is an equity choice with distributional consequences across households and regions.
Finally, operational details are under‑specified: the statutory definitions do not resolve metering boundaries (where utility responsibility ends and customer equipment begins), how separately metered installations should be coordinated with building electrical systems, or how local permitting and interconnection timelines interact with tariffed utility deployments. CPUC implementation will require new guidance and possibly technical standards to prevent project delays, disputes with property owners, and stranded investment risks if technology or charging standards change.
Try it yourself.
Ask a question in plain English, or pick a topic below. Results in seconds.