For those who don't know, capital expenditures that are funded out of a rate case make investor-owned utilities money. If you can get the relevant regulatory body (often a public utility commission) to approve raising rates to cover x dollars of grid resilience projects, the utilities will happily take the money and go forth and implement.
The trick is justifying the spend to said regulators. This is hard with black swan events and regulators that are explicitly tasked with being ratepayer advocates, guarding against the utilities unnecessarily gold-plating things to get a greater rate of return for their investors. It's not like the utilities don't want the money, or the "work" of doing it, or anything like that. Rather, if PG&E went to CPUC and asked for several billion dollars to build a hardened bunker filled with things like transformers that may never be used in the lifetime of the people signing the documents (but the profits realized by the rate of return on the CAPEX will immediately go to investors), they'll likely get laughed out of the room. This issue complicates the discussion about grid resilience, because it can seem to Jeff & Jane Ratepayer (/taxpayer if we're talking national projects) it's all just an excuse to route regular people's money to executives & investors over something that won't happen, the rich get richer, yadda yadda yadda.