The California State Board of Equalization on Wednesday denied Southern California Edison Co.'s appeal of its 2025 unitary property assessment, voting 4–1 to affirm the board-adopted value of $41,664,500,000.

Petitioner Southern California Edison asked the board during a lengthy oral hearing to reduce that value to $35,821,100,000, arguing that the board's State Assessed Properties Division (SAPD) had improperly included in the historical cost indicator assets and liabilities tied to wildfire mitigation and insurance. Petitioner counsel Marty Decassian asked the board to "put yourselves ... in the shoes of a reasonably prudent buyer" and remove or adjust AB 1054 wildfire-mitigation capital, annualize a $2.4 billion initial wildfire insurance fund contribution, and account for ongoing wildfire claims liabilities in the income indicator.

SAPD legal lead David Luhan told the board staff had already adjusted for wildfire-related factors where appropriate and concluded the historical-cost-less-depreciation (HCLD) method remained the most reliable indicator under property-tax rules and the board's Rule 8. "We recommend denying the petition on all issues," Luhan said.

Members focused their questions on three central disputes: whether AB 1054 capital expenditures that earn no equity return should be removed entirely from HCLD; whether the one-time wildfire-fund contribution should be annualized or treated as an intangible to be excluded from taxable value; and whether previously accrued wildfire claims liabilities should reduce property value. Petitioner argued those items alter cash flow and a prospective buyer's view of value; staff countered that some items are nonrecurring or are recoverable through CPUC-approved ratemaking and therefore do not directly reduce the taxable property's value.

Vice Chair Sally Lieber moved to deny the petition; Member Ted Vasquez seconded. Chairman Gaines voted No; Vice Chair Lieber, Member Vasquez, Member Mike Schaffer and Controller Betty Cohen voted Aye. The board's decision means SAPD's adopted 2025 unitary values stand. Under Revenue and Taxation Code section 40, the appeals attorney will prepare a written decision memorializing the board's action.

Why it matters: The case centers on how to value investor-owned utilities in a state where wildfire risk, statutory reforms and rate-making changes have altered insurers' and markets' responses. Petitioner characterized the discrepancy between HCLD and the income (capitalized earning ability) indicator as economic obsolescence; staff replied that the HCLD remains reliable and that staff's adjustments already reflect wildfire risk where appropriate.

What's next: The appeals attorney will draft a written decision reflecting the board's determination under the requirements of Revenue and Taxation Code section 40. The board's judgment affects how wildfire mitigation costs and associated liabilities are treated in future utility valuations and will be relevant to other investor-owned utility appeals.

Attribution: Petitioner arguments and questions were presented by Marty Decassian, counsel for Southern California Edison; technical closing and staff recommendations were presented by David Luhan and other SAPD representatives. Board members asking questions and voting included Chairman Gaines, Vice Chair Lieber, Member Vasquez, Member Schaffer and Controller Cohen.

Ending: The Board recessed for lunch after the vote and will receive the appeals attorney's written decision in due course as required by statute.