WEBVTT 1 00:00:00.100 --> 00:00:04.570 We get to it, um, Ms. Sheriff. 2 00:00:04.570 --> 00:00:06.050 Yes thank you Your Honor, 3 00:00:06.050 --> 00:00:07.860 the one clarification I would add 4 00:00:07.860 --> 00:00:12.380 is the request to have PG&E conduct the redirect 5 00:00:12.380 --> 00:00:15.260 of Mr. Kenny following my cross-examination 6 00:00:15.260 --> 00:00:18.150 of him today while I am here if possible. 7 00:00:18.150 --> 00:00:20.640 If there is any, we can see what we can do. 8 00:00:23.950 --> 00:00:25.770 But with that, let's go ahead 9 00:00:25.770 --> 00:00:28.170 and continue with this panel for now. 10 00:00:30.270 --> 00:00:32.540 So I believe Ms. Kelly are you up next? 11 00:00:32.540 --> 00:00:33.470 Yes I am Your Honor. 12 00:00:33.470 --> 00:00:34.303 Okay, go ahead. 13 00:00:34.303 --> 00:00:35.180 Mr. Strauss did you have-- 14 00:00:35.180 --> 00:00:36.130 I might. 15 00:00:36.130 --> 00:00:39.230 I'd also like to add just a couple questions 16 00:00:39.230 --> 00:00:41.630 if there is time today for this panel as well. 17 00:00:42.530 --> 00:00:43.920 Ah, yes. 18 00:00:43.920 --> 00:00:45.370 Thank you Your Honor. 19 00:00:45.370 --> 00:00:47.160 Go ahead Ms. Kelly. 20 00:00:47.160 --> 00:00:49.240 Thank you Your Honor, thank you. 21 00:00:49.240 --> 00:00:52.310 I believe my questions will be for Mr. Pender. 22 00:00:52.310 --> 00:00:56.980 If you would please turn to page 6-5 of your testimony. 23 00:01:06.350 --> 00:01:07.461 Yes. 24 00:01:07.461 --> 00:01:10.461 (telephone ringing) 25 00:01:14.940 --> 00:01:16.260 I'm there. 26 00:01:16.260 --> 00:01:17.093 Thank you. 27 00:01:18.300 --> 00:01:23.130 At approximately line 22 you say that PG&E 28 00:01:23.130 --> 00:01:28.130 has completed the Enhanced Vegetation Management work 29 00:01:28.770 --> 00:01:32.320 on a total of approximately 2,500 line miles, 30 00:01:32.320 --> 00:01:33.200 is that correct? 31 00:01:33.200 --> 00:01:34.033 That's correct. 32 00:01:34.033 --> 00:01:34.866 Okay. 33 00:01:34.866 --> 00:01:37.850 So what does it take for a line mile 34 00:01:37.850 --> 00:01:40.430 to be designated as completed work? 35 00:01:41.830 --> 00:01:42.670 That's a great question. 36 00:01:42.670 --> 00:01:45.380 So we have a multi-step process 37 00:01:45.380 --> 00:01:48.990 to move from identifying a line to be worked, 38 00:01:48.990 --> 00:01:52.460 through completing the work, validating it, et cetera. 39 00:01:52.460 --> 00:01:54.620 So first we have a pre-inspector, 40 00:01:54.620 --> 00:01:56.880 a vegetation arborist who goes out 41 00:01:56.880 --> 00:02:00.750 and marks the trees along that line that need to be worked. 42 00:02:00.750 --> 00:02:03.990 Now to be clear, Enhanced Vegetation Management 43 00:02:03.990 --> 00:02:05.710 is enhanced because it's above 44 00:02:05.710 --> 00:02:08.210 and beyond compliance requirements. 45 00:02:08.210 --> 00:02:10.690 So generally speaking, compliance requirements 46 00:02:10.690 --> 00:02:12.400 require a radial clearance, 47 00:02:12.400 --> 00:02:14.940 just a circle around our power lines. 48 00:02:14.940 --> 00:02:17.390 Enhanced Vegetation Management goes beyond that, 49 00:02:17.390 --> 00:02:20.920 to removing overhanging branches, extending the circle 50 00:02:20.920 --> 00:02:23.900 or the radial clearance and also identifying hazardous 51 00:02:23.900 --> 00:02:26.810 or at-risk trees adjacent to the power lines 52 00:02:26.810 --> 00:02:30.320 to be treated or to be removed or trimmed as appropriate. 53 00:02:30.320 --> 00:02:33.150 So the pre-inspector as part of the EVM program 54 00:02:33.150 --> 00:02:36.060 is walking the line, marking those trees. 55 00:02:36.060 --> 00:02:39.060 Then a tree crew comes behind that pre-inspector 56 00:02:39.060 --> 00:02:41.600 and performs the work that has bee prescribed. 57 00:02:41.600 --> 00:02:44.760 So that could be removing trees, trimming trees, 58 00:02:44.760 --> 00:02:46.370 whatever the case may be. 59 00:02:46.370 --> 00:02:49.780 When they're done we have a work verification process. 60 00:02:49.780 --> 00:02:53.230 Work verification is performed on 100% 61 00:02:53.230 --> 00:02:55.800 of the Enhanced Vegetation Management miles. 62 00:02:55.800 --> 00:02:57.470 So when the tree crew says complete, 63 00:02:57.470 --> 00:02:59.490 we have a separate inspector, 64 00:02:59.490 --> 00:03:01.460 part of the work verification process, 65 00:03:01.460 --> 00:03:02.570 who makes sure that the work 66 00:03:02.570 --> 00:03:06.870 that they performed was in line with our EVM standard. 67 00:03:08.270 --> 00:03:10.540 If they identify anything that was not in line 68 00:03:10.540 --> 00:03:12.850 with our standard, they mark those trees 69 00:03:12.850 --> 00:03:15.040 that should have been trimmed or something different 70 00:03:15.040 --> 00:03:17.380 should have occurred and then it is re-worked. 71 00:03:17.380 --> 00:03:18.880 It goes back to a tree crew to work again 72 00:03:18.880 --> 00:03:23.430 and then it gets re-work verified to make sure 73 00:03:23.430 --> 00:03:26.010 that it is in compliance with our standard. 74 00:03:26.010 --> 00:03:27.350 And then when all that's completed 75 00:03:27.350 --> 00:03:29.550 then we call a mile complete. 76 00:03:29.550 --> 00:03:33.560 Additionally, the fourth quarter of last year we added a QA, 77 00:03:33.560 --> 00:03:37.230 quality assurance step where we had a separate team 78 00:03:37.230 --> 00:03:40.890 within PG&E take a sampling of all those miles 79 00:03:40.890 --> 00:03:42.490 that had gone through all those other steps 80 00:03:42.490 --> 00:03:44.420 and was considered complete to say, 81 00:03:44.420 --> 00:03:46.530 hey if we looked at it with fresh eyes, 82 00:03:46.530 --> 00:03:48.640 would we say that those miles are complete 83 00:03:48.640 --> 00:03:50.500 and in line with our standard. 84 00:03:50.500 --> 00:03:52.670 So we have a couple of quality steps 85 00:03:52.670 --> 00:03:54.380 and certainly a couple of process steps 86 00:03:54.380 --> 00:03:57.040 to complete a mile of Enhanced Vegetation Management. 87 00:03:58.020 --> 00:03:59.700 And so what have been the results 88 00:03:59.700 --> 00:04:03.400 of the Quality Assurance performed to date? 89 00:04:03.400 --> 00:04:08.390 So there's a work verification process right 90 00:04:10.270 --> 00:04:11.850 and there's a quality assurance step 91 00:04:11.850 --> 00:04:15.180 which we pretty much only establish in the fourth quarter. 92 00:04:15.180 --> 00:04:20.180 That sampling basis found approximately 98% pass rate. 93 00:04:21.120 --> 00:04:23.600 So the miles we had said were complete, 94 00:04:23.600 --> 00:04:26.970 that quality assurance step validated it. 95 00:04:26.970 --> 00:04:28.600 98% of what they sampled was 96 00:04:28.600 --> 00:04:30.650 in fact in line with our standard. 97 00:04:31.900 --> 00:04:35.350 So that's 2% non-compliance. 98 00:04:35.350 --> 00:04:38.930 That's 2% that were assessed to not be perfectly 99 00:04:38.930 --> 00:04:40.700 in compliance with our standard, yes. 100 00:04:43.160 --> 00:04:46.260 Okay, then turning to, 101 00:04:54.464 --> 00:04:59.420 I had previously identified MCE exhibit, MC EX-2. 102 00:05:03.987 --> 00:05:05.180 Do you have that with you? 103 00:05:05.180 --> 00:05:06.013 I believe so. 104 00:05:06.013 --> 00:05:08.390 Is that excerpt from the 2019 Wildfire Safety Program? 105 00:05:08.390 --> 00:05:09.830 Correct. 106 00:05:09.830 --> 00:05:14.490 So if you go to page 136 of that document. 107 00:05:18.830 --> 00:05:21.010 Is at the top of that page, 108 00:05:22.570 --> 00:05:27.570 this relates to quality assurance results in HFTD areas. 109 00:05:29.570 --> 00:05:31.440 And it says that the target 110 00:05:31.440 --> 00:05:35.880 is met by achieving 92% meets expectations. 111 00:05:35.880 --> 00:05:37.970 So what I am understanding that you're saying today 112 00:05:37.970 --> 00:05:40.660 is PG&E is meeting 98%? 113 00:05:40.660 --> 00:05:45.660 So this language which was written in early 2019 114 00:05:46.110 --> 00:05:47.860 as part of our February submittal 115 00:05:47.860 --> 00:05:50.080 of the Wildfire Safety Plan. 116 00:05:50.080 --> 00:05:53.090 What we had in mind when we discussed this 117 00:05:53.090 --> 00:05:55.260 as you look at the top of page 136, 118 00:05:55.260 --> 00:05:57.040 it references that this QA Review 119 00:05:57.040 --> 00:06:00.910 will be performed on 100% of the EVM work. 120 00:06:00.910 --> 00:06:02.620 This is in reference essentially 121 00:06:02.620 --> 00:06:05.130 to our work verification process. 122 00:06:05.130 --> 00:06:09.470 And so, every mile is assessed under work verification 123 00:06:09.470 --> 00:06:13.090 and that was what we initially put the 92% target on. 124 00:06:15.890 --> 00:06:20.720 And what was the figure for the work verification target 125 00:06:20.720 --> 00:06:22.680 that PG&E has achieved to date? 126 00:06:23.570 --> 00:06:27.670 So as has been filed in some other environments, 127 00:06:27.670 --> 00:06:31.770 to the CPUC as well as to other venues, 128 00:06:31.770 --> 00:06:36.770 we achieved around 63%, first pass quality clearance 129 00:06:38.220 --> 00:06:40.300 on this work verification process. 130 00:06:45.980 --> 00:06:50.980 And can you explain what that 63% is a percentage of? 131 00:06:51.460 --> 00:06:54.010 So of 100% of the miles that were completed, 132 00:06:54.010 --> 00:06:57.720 which ended up being 2,500, about 2,500 miles last year, 133 00:06:57.720 --> 00:07:01.420 we did a work verification and approximately 63% 134 00:07:01.420 --> 00:07:04.130 of those miles were good to go, 135 00:07:04.130 --> 00:07:06.960 met our standard from the first check. 136 00:07:06.960 --> 00:07:09.820 The other 37% needed some rework, 137 00:07:10.660 --> 00:07:13.830 whether it was one tree or a number of trees. 138 00:07:13.830 --> 00:07:17.540 The 37% of the miles, when first assessed 139 00:07:17.540 --> 00:07:19.600 after the tree crew had completed their work, 140 00:07:19.600 --> 00:07:22.060 we found some rework that needed to be completed 141 00:07:22.060 --> 00:07:24.550 and then we would verify the miles again. 142 00:07:27.650 --> 00:07:32.650 So are you saying that in 63% of cases 143 00:07:32.770 --> 00:07:36.160 there were zero trees that had any exceptions per mile? 144 00:07:37.380 --> 00:07:38.430 That's one way to think of it. 145 00:07:38.430 --> 00:07:42.830 That all of the vegetation in that segment of line complied 146 00:07:42.830 --> 00:07:43.940 with our standard, so yes, 147 00:07:43.940 --> 00:07:46.690 there were zero exception trees on 63% of the miles. 148 00:07:53.400 --> 00:07:57.950 And for the remaining 37% 149 00:08:02.238 --> 00:08:06.163 what on average were the percentage of exception trees, 150 00:08:10.220 --> 00:08:13.100 or the number of exception trees per mile? 151 00:08:13.100 --> 00:08:14.780 Yeah I apologize, I don't have any 152 00:08:14.780 --> 00:08:16.492 of those stats off the top of my head. 153 00:08:16.492 --> 00:08:21.200 We have that information in our system, but I dunno. 154 00:08:21.200 --> 00:08:22.260 Okay. 155 00:08:22.260 --> 00:08:25.280 And I do note on the page prior, 156 00:08:25.280 --> 00:08:29.887 I'm looking at the same exhibit, MC EX-2, Page 135. 157 00:08:32.040 --> 00:08:34.520 These quality assurance results, 158 00:08:34.520 --> 00:08:38.200 the way that this is stated, calculate this as the number 159 00:08:38.200 --> 00:08:40.730 of trees correctly worked to the EMV 160 00:08:40.730 --> 00:08:45.730 or drop tree mortality scope divided by all in scope trees. 161 00:08:47.530 --> 00:08:50.660 So it sounds like a percentage of trees, is that correct? 162 00:08:50.660 --> 00:08:51.670 That's correct. 163 00:08:51.670 --> 00:08:53.560 You're right, I may have misstated it 164 00:08:53.560 --> 00:08:55.740 or it was unclear in what I initially stated. 165 00:08:55.740 --> 00:09:00.070 The 63% is of the trees in the scope of work. 166 00:09:00.070 --> 00:09:02.740 In the trees within the 2,500 miles, 167 00:09:02.740 --> 00:09:06.300 63% were good from the initial work verification 168 00:09:06.300 --> 00:09:09.390 and 37% needed additional work. 169 00:09:11.720 --> 00:09:14.770 So if I'm walking down a line mile 170 00:09:15.810 --> 00:09:20.510 and I'm counting 100 trees, 37% of those trees 171 00:09:22.840 --> 00:09:25.560 were not correctly worked, is that correct? 172 00:09:27.022 --> 00:09:29.540 Yeah, that is a correct understanding 173 00:09:29.540 --> 00:09:32.000 that after the tree crew had completed their work, 174 00:09:32.000 --> 00:09:34.330 there were 37 trees out of 100 175 00:09:34.330 --> 00:09:35.830 that still needed some rework. 176 00:09:36.860 --> 00:09:41.860 Matt, to be clear, in our first quality process 177 00:09:42.390 --> 00:09:45.320 those trees that were incompletely worked 178 00:09:46.160 --> 00:09:49.510 were then redirected for rework 179 00:09:49.510 --> 00:09:52.940 before we declared those miles complete. 180 00:09:52.940 --> 00:09:54.720 Absolutely correct. 181 00:09:54.720 --> 00:09:56.750 And can you clarify again what the percentage 182 00:09:56.750 --> 00:10:01.120 of trees that were non-compliant 183 00:10:03.250 --> 00:10:06.830 upon completion as you're defining it? 184 00:10:06.830 --> 00:10:08.940 Yeah, so after the first pass 185 00:10:08.940 --> 00:10:10.030 we would have done our rework 186 00:10:10.030 --> 00:10:13.150 and then we would have work verified a second time. 187 00:10:14.610 --> 00:10:16.410 Once all of that was done and we said 188 00:10:16.410 --> 00:10:19.740 that mile was complete, we did this QA sample 189 00:10:19.740 --> 00:10:22.200 in the fourth quarter where we didn't do every mile, 190 00:10:22.200 --> 00:10:26.860 but we sampled miles and 98% of those 191 00:10:26.860 --> 00:10:28.590 were within our EVM standard. 192 00:10:30.110 --> 00:10:33.360 And is that consistent with industry best practices? 193 00:10:35.060 --> 00:10:37.840 There's no industry best practices in this space. 194 00:10:37.840 --> 00:10:41.260 We are going above and beyond any regulatory norms. 195 00:10:41.260 --> 00:10:43.440 There are few companies who do anything like this 196 00:10:43.440 --> 00:10:45.230 in terms of the scope and scale 197 00:10:45.230 --> 00:10:46.770 of this vegetation management effort. 198 00:10:46.770 --> 00:10:51.380 So no, there's no benchmark on this metric, which is, 199 00:10:51.380 --> 00:10:54.520 if you're doing a program above and beyond compliant, 200 00:10:54.520 --> 00:10:57.060 what's your quality outcomes in that space. 201 00:10:58.040 --> 00:11:03.040 And did you refer to the vegetation management plans 202 00:11:03.040 --> 00:11:05.100 of the other utilities to determine 203 00:11:05.100 --> 00:11:09.160 how your metrics aligned with theirs? 204 00:11:09.160 --> 00:11:11.450 Yeah, I mean we've been in regular contact with, 205 00:11:11.450 --> 00:11:14.010 particularly the other two California IOUs who operate 206 00:11:14.010 --> 00:11:16.680 in a somewhat similar environment 207 00:11:16.680 --> 00:11:18.640 about how they operate their programs, 208 00:11:18.640 --> 00:11:20.670 how they measure all those things. 209 00:11:21.850 --> 00:11:26.740 And so, are you aware that SDG&E's non-compliance rate 210 00:11:26.740 --> 00:11:28.120 is approximately 1%? 211 00:11:29.100 --> 00:11:32.420 If they're measuring a slightly different thing. 212 00:11:32.420 --> 00:11:36.240 My understanding of their measure of quality 213 00:11:36.240 --> 00:11:39.410 is not the same as the scope 214 00:11:39.410 --> 00:11:41.660 of our enhanced Vegetation Management Program. 215 00:11:41.660 --> 00:11:43.480 The scope of our program, 216 00:11:43.480 --> 00:11:45.720 in terms of removing all overhangs, 217 00:11:45.720 --> 00:11:49.810 identifying at-risk trees is more complex 218 00:11:49.810 --> 00:11:53.650 and drives a higher volume of work than any 219 00:11:53.650 --> 00:11:56.510 of STG&E's vegetation programs for example. 220 00:11:56.510 --> 00:11:57.343 Okay. 221 00:11:57.343 --> 00:12:02.220 And approximately how many trees per mile does PG&E have? 222 00:12:04.540 --> 00:12:08.100 So I don't have a specific number on that. 223 00:12:08.100 --> 00:12:10.320 You can take really high-level numbers 224 00:12:10.320 --> 00:12:13.480 like we have approximately 100 million trees 225 00:12:13.480 --> 00:12:16.620 with the risk of falling into our lines. 226 00:12:16.620 --> 00:12:18.760 We have on the distribution system, 227 00:12:18.760 --> 00:12:22.910 81,000 overhead distribution circuit miles. 228 00:12:22.910 --> 00:12:26.740 So you could divide those and get some per-mile estimate, 229 00:12:26.740 --> 00:12:29.700 but of course it varies widely from the urban parts 230 00:12:29.700 --> 00:12:32.090 of our service territory to the rural 231 00:12:32.090 --> 00:12:34.280 or forested parts of our service territory. 232 00:12:34.280 --> 00:12:36.850 So thinking specifically about the high threat 233 00:12:36.850 --> 00:12:39.590 fire districts, what is that approximate number 234 00:12:39.590 --> 00:12:41.060 of trees per mile? 235 00:12:41.060 --> 00:12:42.410 I don't have that number. 236 00:12:47.000 --> 00:12:48.750 In the literature that I've read, 237 00:12:49.620 --> 00:12:51.620 it can be quite a wide range, 238 00:12:51.620 --> 00:12:56.547 but somewhere between 800 trees per mile and I believe, 239 00:13:04.530 --> 00:13:08.690 I have to find the figure, somewhere around 1,400 or so. 240 00:13:08.690 --> 00:13:10.300 Does that sound like about the scale 241 00:13:10.300 --> 00:13:11.480 that we're talking about? 242 00:13:11.480 --> 00:13:13.080 Those numbers don't surprise me, 243 00:13:13.080 --> 00:13:15.340 depending on where you sample, or something, you know, 244 00:13:15.340 --> 00:13:17.170 which miles, which counties, but... 245 00:13:28.080 --> 00:13:29.710 So Ms. Kelly, 246 00:13:29.710 --> 00:13:31.990 I think this was carryover time from-- 247 00:13:31.990 --> 00:13:32.860 Yes. 248 00:13:32.860 --> 00:13:34.800 Ms. Cain that you'd asked for 10 minutes on. 249 00:13:34.800 --> 00:13:36.810 So let's do a time check. 250 00:13:36.810 --> 00:13:37.643 Okay. 251 00:13:37.643 --> 00:13:39.710 I think I have two more questions. 252 00:13:41.080 --> 00:13:42.420 I think we can accommodate that. 253 00:13:42.420 --> 00:13:43.490 Thank you. 254 00:13:43.490 --> 00:13:48.490 And then so how, for purposes of compliance with law 255 00:13:52.370 --> 00:13:57.370 and the PG&E plan, how are you defining compliance 256 00:13:57.490 --> 00:14:00.800 for purposes of this program? 257 00:14:00.800 --> 00:14:03.080 So just to be clear, you mentioned compliance 258 00:14:03.080 --> 00:14:05.540 with two things and those are very separate things. 259 00:14:05.540 --> 00:14:08.760 So compliance with the law is about the radial clearance 260 00:14:08.760 --> 00:14:10.150 around our power lines and making sure 261 00:14:10.150 --> 00:14:12.760 that no trees get too close to power lines. 262 00:14:12.760 --> 00:14:15.400 We have a number of processes, different 263 00:14:15.400 --> 00:14:17.840 than what I previously discussed related 264 00:14:17.840 --> 00:14:20.710 to EVM to maintain compliance 265 00:14:20.710 --> 00:14:22.840 with radial clearance regulations. 266 00:14:22.840 --> 00:14:25.730 So we have a routine Veg Management Program 267 00:14:25.730 --> 00:14:29.060 that inspects every line on at least an annual basis. 268 00:14:29.060 --> 00:14:32.350 We have quality control and quality assurance programs 269 00:14:32.350 --> 00:14:33.900 that check that work. 270 00:14:33.900 --> 00:14:36.250 Quality control checks the work that was performed. 271 00:14:36.250 --> 00:14:38.260 Quality assurance looks at samples 272 00:14:38.260 --> 00:14:40.920 of our system at any time of the year 273 00:14:40.920 --> 00:14:43.130 and goes and looks at: Are all the trees 274 00:14:43.130 --> 00:14:45.400 in compliance with the regulation? 275 00:14:45.400 --> 00:14:49.780 And we have above 99% pass rate 276 00:14:49.780 --> 00:14:51.740 on that quality assurance program. 277 00:14:51.740 --> 00:14:53.520 Related to the legal requirement? 278 00:14:53.520 --> 00:14:54.353 Yes. 279 00:14:54.353 --> 00:14:55.186 Okay. Yes. 280 00:14:55.186 --> 00:14:56.990 So that's legal compliance. 281 00:14:56.990 --> 00:14:59.400 And then as it relates to our Wildfire Safety Plan 282 00:14:59.400 --> 00:15:01.820 or our Wildfire Mitigation Plan, 283 00:15:01.820 --> 00:15:04.110 we have all the programs I laid out previously 284 00:15:04.110 --> 00:15:07.900 to make sure that we do the work, we check the work, 285 00:15:07.900 --> 00:15:10.290 we rework if necessary and then we validate 286 00:15:10.290 --> 00:15:12.230 that we've completed the work. 287 00:15:12.230 --> 00:15:14.740 So as it relates to compliance 288 00:15:14.740 --> 00:15:15.890 with our Wildfire Mitigation Plan, 289 00:15:15.890 --> 00:15:17.910 we've put those steps in place to make sure 290 00:15:17.910 --> 00:15:20.500 that when we say we've done enough miles 291 00:15:20.500 --> 00:15:24.010 to meet our obligation, our commitment, 292 00:15:25.090 --> 00:15:27.790 they've been thoroughly validated. 293 00:15:27.790 --> 00:15:31.970 And what is the quality threshold of that. 294 00:15:31.970 --> 00:15:34.860 You'd mentioned for compliance with law about 99% 295 00:15:34.860 --> 00:15:39.300 and then for the EVM, what would that be? 296 00:15:41.190 --> 00:15:45.010 Well as I mentioned, we do 100% work verification 297 00:15:45.010 --> 00:15:48.840 and then rework it if necessary until it passes 298 00:15:48.840 --> 00:15:49.720 that work verification. 299 00:15:49.720 --> 00:15:54.720 So we have no threshold that's close enough, right, 300 00:15:54.890 --> 00:15:59.110 until 100% of trees on a segment have been assessed to be 301 00:15:59.110 --> 00:16:03.190 in compliance with our standard on the Wildfire Safety Plan 302 00:16:03.190 --> 00:16:05.280 we won't count that mile as complete. 303 00:16:05.280 --> 00:16:08.160 So when we say 2,500 miles, those 2,500 miles 304 00:16:08.160 --> 00:16:13.110 meet a 100% standard for all trees on that span, 305 00:16:13.110 --> 00:16:15.530 on that mile being completed to standard. 306 00:16:17.250 --> 00:16:19.180 I guess what I don't understand is you had said 307 00:16:19.180 --> 00:16:23.743 that there was a 98% QA achievement, 308 00:16:27.030 --> 00:16:28.130 on the work performed? 309 00:16:29.080 --> 00:16:34.080 Yeah, so as another quality check has sampled those miles 310 00:16:35.760 --> 00:16:39.110 and identified a relatively small number 311 00:16:39.110 --> 00:16:42.370 that may require further look or rework 312 00:16:42.370 --> 00:16:44.140 and if so we will send that back 313 00:16:44.140 --> 00:16:46.690 through our operational team to rework those miles. 314 00:16:51.170 --> 00:16:55.310 And is it your team, or the chief compliance officer 315 00:16:55.310 --> 00:16:58.470 that defines what compliance is? 316 00:16:59.450 --> 00:17:03.690 So the electric operations team has set up the processes 317 00:17:03.690 --> 00:17:06.150 and the standards related to this program, 318 00:17:06.150 --> 00:17:08.860 from the field work to the quality control 319 00:17:08.860 --> 00:17:11.650 or work verification to the quality assurance program. 320 00:17:11.650 --> 00:17:16.650 So all the standards have been established 321 00:17:16.720 --> 00:17:19.480 and owned by the electric operations department. 322 00:17:19.480 --> 00:17:21.357 Okay, I have no further questions. 323 00:17:21.357 --> 00:17:22.760 Thank you Ms. Kelly. 324 00:17:22.760 --> 00:17:24.300 Let's go off the record a minute. 325 00:17:26.100 --> 00:17:27.800 I think it might be me Your Honor. 326 00:17:30.560 --> 00:17:34.060 (speaking off microphone) 327 00:17:51.040 --> 00:17:52.530 On the record Ms. Sheriff. 328 00:17:53.780 --> 00:17:54.720 Thank you Your Honor. 329 00:17:54.720 --> 00:17:55.770 Good afternoon. 330 00:17:55.770 --> 00:17:57.020 My name is Nora Sheriff. 331 00:17:57.020 --> 00:17:59.020 I represent the California Large Energy 332 00:17:59.020 --> 00:18:01.830 Consumer's Association or CLECA. 333 00:18:01.830 --> 00:18:04.490 CLECA is made up of large power customers, 334 00:18:04.490 --> 00:18:07.540 industrial customers, manufacturing customers 335 00:18:08.380 --> 00:18:10.070 of Pacific Gas and Electric Company 336 00:18:10.070 --> 00:18:12.680 and Southern California Edison Company. 337 00:18:12.680 --> 00:18:15.390 I have a few specific questions 338 00:18:15.390 --> 00:18:17.670 which I will direct first to Mr. Pender. 339 00:18:17.670 --> 00:18:19.580 Then I have a different set of questions 340 00:18:19.580 --> 00:18:24.580 for Ms. Maratukulam, if that's correct? 341 00:18:25.480 --> 00:18:26.810 Thank you. 342 00:18:26.810 --> 00:18:31.270 So Mr. Pender, at page 6-7 of your testimony 343 00:18:31.270 --> 00:18:36.090 in what's been marked for identification as exhibit PG&E1. 344 00:18:36.090 --> 00:18:41.090 You state that quote, "PG&E recognizes the seriousness 345 00:18:41.170 --> 00:18:46.170 "of each PSPS event however and has an actively taking steps 346 00:18:46.820 --> 00:18:50.440 "to reduce the duration, frequency and impact 347 00:18:50.440 --> 00:18:54.110 "of PSPS events as detailed in Section E below." 348 00:18:55.260 --> 00:18:59.220 And your colleague drafted Section E. 349 00:18:59.220 --> 00:19:01.170 Did you review her draft testimony? 350 00:19:04.140 --> 00:19:06.710 I didn't review this exact draft testimony, 351 00:19:06.710 --> 00:19:10.000 but we've been in regular contact about the aspects 352 00:19:10.000 --> 00:19:11.560 of the PSPS program as part 353 00:19:11.560 --> 00:19:13.260 of our Wildfire mitigation effort. 354 00:19:15.570 --> 00:19:18.640 Are you aware of the vast number of customers 355 00:19:18.640 --> 00:19:23.350 affected by the fall of 2019 PSP events that received 356 00:19:23.350 --> 00:19:28.350 no notice of those fall 2019 PSPS events from PG&E? 357 00:19:30.740 --> 00:19:35.740 I'm not the expert on the operational aspects 358 00:19:36.850 --> 00:19:41.750 of our 2019 or 2020 PSPS events, so no. 359 00:19:44.410 --> 00:19:47.420 Have you reviewed any of President Batjer's rulings 360 00:19:47.420 --> 00:19:50.850 regarding the fall 2019 PSPS events? 361 00:19:51.780 --> 00:19:54.350 I'm peripherally aware of those rulings 362 00:19:54.350 --> 00:19:57.670 as well as the ongoing proceedings before the CPUC, 363 00:19:57.670 --> 00:20:00.840 but again, not the point person on those activities. 364 00:20:02.330 --> 00:20:03.760 Okay, would it surprise you to note 365 00:20:03.760 --> 00:20:06.350 that in one of her rulings she specifically identified 366 00:20:06.350 --> 00:20:10.160 that there were approximately 23,000 customers 367 00:20:10.160 --> 00:20:14.160 out of the 729,000 customers that were affected 368 00:20:14.160 --> 00:20:19.160 in the fall 2019 PSPS events that got no notice from PG&E? 369 00:20:20.610 --> 00:20:22.240 Objection to foundation. 370 00:20:22.240 --> 00:20:23.110 Sustained. 371 00:20:23.110 --> 00:20:25.590 It's not clear that this is the right witness for this. 372 00:20:25.590 --> 00:20:30.140 He's pretty clearly referring to Section E, 373 00:20:30.140 --> 00:20:31.020 which is not his. 374 00:20:32.240 --> 00:20:36.180 In connection with the efforts to reduce PSPS impacts, 375 00:20:37.090 --> 00:20:39.220 have you considered the different types 376 00:20:39.220 --> 00:20:41.410 of customers that you have? 377 00:20:44.680 --> 00:20:49.680 Our focus on reducing PSPS impacts as we've laid out 378 00:20:50.010 --> 00:20:53.080 in this filing as well as more extensively 379 00:20:53.080 --> 00:20:55.810 in our Wildfire Mitigation Plan are focused 380 00:20:55.810 --> 00:20:58.730 on reducing PSPS impacts to the largest number 381 00:20:58.730 --> 00:21:01.930 of customers possible and then for the customers 382 00:21:01.930 --> 00:21:04.220 who are still impacted by PSPS events 383 00:21:04.220 --> 00:21:06.220 shortening the duration of those events. 384 00:21:07.220 --> 00:21:11.900 I'm not aware that our efforts have been largely influenced 385 00:21:11.900 --> 00:21:13.730 by the makeup of those customers 386 00:21:14.740 --> 00:21:18.530 beyond benefiting the largest populations 387 00:21:18.530 --> 00:21:20.330 of customers as quickly as possible. 388 00:21:21.230 --> 00:21:23.970 And I would invite your colleague, Ms. Maratukulam, 389 00:21:23.970 --> 00:21:26.800 if you have any additional response, 390 00:21:26.800 --> 00:21:28.130 I would like to hear it. 391 00:21:28.130 --> 00:21:30.130 Can you repeat the question? 392 00:21:30.130 --> 00:21:34.570 Whether or not PG&E has considered the different types 393 00:21:34.570 --> 00:21:39.100 of customers that it has, residential, commercial, 394 00:21:39.100 --> 00:21:42.310 industrial when looking at the efforts 395 00:21:42.310 --> 00:21:45.000 that you're undertaking to reduce the impacts 396 00:21:45.000 --> 00:21:47.360 of the public safety power shutoff events. 397 00:21:47.360 --> 00:21:50.490 Yes, PG&E has considered the different customer types 398 00:21:50.490 --> 00:21:53.510 and is targeting both our outreach in advance 399 00:21:53.510 --> 00:21:56.080 of the PSPS season and during, accordingly. 400 00:21:56.990 --> 00:21:57.823 Okay. 401 00:21:57.823 --> 00:22:00.390 So have you, it sounds like you 402 00:22:00.390 --> 00:22:03.780 have considered the different potential impacts 403 00:22:03.780 --> 00:22:06.510 to the surrounding area associated with the sudden loss 404 00:22:06.510 --> 00:22:09.480 of power for those different types of customers? 405 00:22:10.540 --> 00:22:12.520 We're working with our customers to ensure 406 00:22:12.520 --> 00:22:15.180 that they are aware of the potential of de-energization 407 00:22:15.180 --> 00:22:18.160 in advance of the season and then during events work 408 00:22:18.160 --> 00:22:20.790 to ensure that they are notified if they are within scope 409 00:22:20.790 --> 00:22:24.070 of a given event so they can prepare accordingly. 410 00:22:24.070 --> 00:22:27.280 Are you aware that a sudden loss of power 411 00:22:27.280 --> 00:22:32.280 to a large industrial customer with complex machinery, 412 00:22:32.830 --> 00:22:36.740 hazardous materials, could have a very different impact 413 00:22:36.740 --> 00:22:38.370 on the surrounding environment 414 00:22:38.370 --> 00:22:41.270 versus the loss of power to a home or an office? 415 00:22:42.140 --> 00:22:44.230 We recognize that the loss of power 416 00:22:44.230 --> 00:22:47.650 and its effects vary from customer type, yes. 417 00:22:54.340 --> 00:22:58.430 And one critical way to reduce the impact of a PSPS event 418 00:22:58.430 --> 00:23:00.660 is to ensure that all customers 419 00:23:00.660 --> 00:23:02.870 that will be impacted actually have notice. 420 00:23:02.870 --> 00:23:03.740 Correct? 421 00:23:03.740 --> 00:23:06.620 Yes, we strive to ensure that all customers 422 00:23:06.620 --> 00:23:09.420 potentially affected by a given PSPS event are notified. 423 00:23:11.592 --> 00:23:14.650 And if we could turn to page 6-12 of your testimony, 424 00:23:21.910 --> 00:23:25.580 there's only one mention here about improving communications 425 00:23:25.580 --> 00:23:27.620 with end use customers, correct? 426 00:23:29.720 --> 00:23:32.470 Are you referring to a specific line on this page? 427 00:23:36.790 --> 00:23:40.470 Yeah, the first bullet, line 27. 428 00:23:49.790 --> 00:23:52.790 So this line does point to our expected 429 00:23:52.790 --> 00:23:55.520 notification cadence when and where possible, 430 00:23:55.520 --> 00:23:58.160 given weather forecasting capabilities, 431 00:23:58.160 --> 00:24:01.730 to notify customers potentially affected by an event. 432 00:24:01.730 --> 00:24:04.450 Right, and of all the pages of testimony, 433 00:24:04.450 --> 00:24:07.380 there's about four in your Section E, 434 00:24:07.380 --> 00:24:09.080 this is the only one that talks 435 00:24:09.080 --> 00:24:11.480 about notification to customers, correct? 436 00:24:19.534 --> 00:24:20.367 I believe that is the case. 437 00:24:20.367 --> 00:24:25.367 Okay, how long have you been the Director of PSPS events? 438 00:24:25.400 --> 00:24:27.060 A little over one year. 439 00:24:27.060 --> 00:24:29.360 Okay, so this was your role in the 440 00:24:29.360 --> 00:24:30.950 fall of 2019? 441 00:24:30.950 --> 00:24:31.783 It was. 442 00:24:34.940 --> 00:24:38.460 At page 6-11, you refer to transmission assets 443 00:24:38.460 --> 00:24:40.750 in the scope of PSPS events. 444 00:24:44.110 --> 00:24:48.540 Is that testimony intended to state that the officer 445 00:24:48.540 --> 00:24:51.110 in charge decides if a transmission line 446 00:24:51.110 --> 00:24:53.470 will be impacted in a PSPS event? 447 00:24:54.720 --> 00:24:56.700 Yes, there are several key decision points 448 00:24:56.700 --> 00:25:01.380 that our officer in charge makes during PSPS events 449 00:25:01.380 --> 00:25:04.540 and one of those is the scope of the event, specifically, 450 00:25:04.540 --> 00:25:06.440 transmission, as well as distribution. 451 00:25:07.380 --> 00:25:10.860 Do you know who communicates that specific information, 452 00:25:10.860 --> 00:25:13.240 the inclusion of a transmission line, 453 00:25:13.240 --> 00:25:15.010 to the PG&E account reps? 454 00:25:16.790 --> 00:25:19.100 As part of our scoping process, 455 00:25:19.100 --> 00:25:21.470 our Planning and Intelligence Section 456 00:25:21.470 --> 00:25:23.760 within our Emergency Operations Center 457 00:25:24.720 --> 00:25:28.650 is tasked with determining the scope of the event, 458 00:25:28.650 --> 00:25:30.810 both the assets within the scope 459 00:25:30.810 --> 00:25:33.890 and the customers served by those assets. 460 00:25:33.890 --> 00:25:37.800 That information is handed to our customer strategy officer, 461 00:25:37.800 --> 00:25:39.720 and the customer team then 462 00:25:39.720 --> 00:25:41.520 takes over notification accordingly. 463 00:25:42.510 --> 00:25:45.970 And where does the customer account rep fit within 464 00:25:45.970 --> 00:25:49.210 that customer strategy officer description you just gave? 465 00:25:49.210 --> 00:25:51.570 If they are part of that section of the EOC. 466 00:25:53.110 --> 00:25:55.610 What's the timing of that information provision? 467 00:25:57.814 --> 00:26:00.670 They are provided that information as soon as the scope 468 00:26:00.670 --> 00:26:02.580 of the event is determined. 469 00:26:02.580 --> 00:26:04.780 Is that what occurred in the fall of 2019? 470 00:26:06.649 --> 00:26:08.300 Yes. 471 00:26:08.300 --> 00:26:09.133 Without fail? 472 00:26:11.150 --> 00:26:12.540 And to clarify, your question it is 473 00:26:12.540 --> 00:26:17.540 that the customer section within the EOC was made aware 474 00:26:18.020 --> 00:26:21.530 of the customers that had been identified as 475 00:26:21.530 --> 00:26:23.940 within the scope of the potential event? 476 00:26:25.050 --> 00:26:28.050 Yes and then the inclusion of transmission lines. 477 00:26:28.050 --> 00:26:31.130 Yes, there are several stages during the process where, 478 00:26:31.130 --> 00:26:33.510 given the complexity of the transmission system, 479 00:26:33.510 --> 00:26:36.080 we are evaluating the potential full scope 480 00:26:36.080 --> 00:26:40.160 of transmission assets will be, so upon initial scope-- 481 00:26:40.160 --> 00:26:41.250 Your Honor, excuse me. 482 00:26:41.250 --> 00:26:44.740 I asked if that's what happened in the fall of 2019. 483 00:26:44.740 --> 00:26:47.380 I think you both kind of wandered around. 484 00:26:47.380 --> 00:26:50.320 Why don't you clarify exactly what you're asking, 485 00:26:50.320 --> 00:26:51.520 and she can answer that? 486 00:26:56.246 --> 00:26:58.170 Are you aware that some customers served, 487 00:26:58.170 --> 00:27:02.300 that the transmission level, were told in October 2019 488 00:27:02.300 --> 00:27:04.810 that their facilities would not be in the scope 489 00:27:04.810 --> 00:27:08.280 of the pending PSPS events, but they actually were 490 00:27:08.280 --> 00:27:11.490 within the scope and they were shutoff without any notice? 491 00:27:12.380 --> 00:27:13.870 Objection, Foundation. 492 00:27:13.870 --> 00:27:14.703 I asked-- 493 00:27:14.703 --> 00:27:15.536 Overruled. 494 00:27:15.536 --> 00:27:17.200 If she was aware. 495 00:27:17.200 --> 00:27:19.750 I am not familiar with specific customer, 496 00:27:19.750 --> 00:27:22.660 transmission level customers who experienced that. 497 00:27:22.660 --> 00:27:25.460 I did read in the data request provided 498 00:27:25.460 --> 00:27:27.940 by CLECA some assertion that that was the case. 499 00:27:34.970 --> 00:27:38.903 So on page 6-11, at lines 12 to 13, 500 00:27:41.600 --> 00:27:44.160 you talk about the incident command structure 501 00:27:44.160 --> 00:27:46.890 and the continual monitoring of the situation 502 00:27:46.890 --> 00:27:48.990 and continuous updating. 503 00:27:52.910 --> 00:27:56.640 Has PG&E considered sharing these continuous updates 504 00:27:56.640 --> 00:28:00.930 directly with the actual account reps who are dealing 505 00:28:00.930 --> 00:28:03.920 with customers in real time during events? 506 00:28:03.920 --> 00:28:06.630 So not to a strategy officer, 507 00:28:06.630 --> 00:28:08.230 but directly to an account rep? 508 00:28:11.490 --> 00:28:13.600 The way that the incident command structure works 509 00:28:13.600 --> 00:28:17.510 within our EOC is that information is cascaded accordingly 510 00:28:17.510 --> 00:28:19.510 throughout the sections that require it. 511 00:28:20.610 --> 00:28:22.570 Would you consider cutting out some 512 00:28:22.570 --> 00:28:26.380 of those cascading steps to provide information 513 00:28:26.380 --> 00:28:29.280 on a more timely basis directly to the people who need it? 514 00:28:30.300 --> 00:28:32.940 We strive to follow incident command structure 515 00:28:32.940 --> 00:28:35.870 in all of our emergency response events. 516 00:28:35.870 --> 00:28:39.060 We are executing them as quickly as possible 517 00:28:39.060 --> 00:28:41.390 and we believe that that system is the most efficient 518 00:28:41.390 --> 00:28:44.070 on delivering on the objectives of the program. 519 00:28:44.070 --> 00:28:44.970 So is that a no? 520 00:28:46.591 --> 00:28:50.140 I believe that we are almost directly 521 00:28:50.140 --> 00:28:52.750 through the organization of the EOC 522 00:28:52.750 --> 00:28:54.240 and its incident command structure, 523 00:28:54.240 --> 00:28:57.470 effectively communicating to customer account managers 524 00:28:57.470 --> 00:28:59.770 who are then communicating with our customers. 525 00:29:02.150 --> 00:29:02.983 So, Ms. Sheriff, 526 00:29:02.983 --> 00:29:05.560 you've gone over your eight-minute estimate. 527 00:29:07.242 --> 00:29:08.520 Do you know how much more you have? 528 00:29:10.967 --> 00:29:12.530 I have four more questions. 529 00:29:15.720 --> 00:29:20.173 At page 6-12, lines 24 to 25, you state 530 00:29:21.530 --> 00:29:23.840 that the utility has implemented measures 531 00:29:23.840 --> 00:29:27.770 to mitigate the impact of PSPS events on its customers. 532 00:29:27.770 --> 00:29:30.620 So are those measures that have already been implemented? 533 00:29:32.050 --> 00:29:33.390 Yes. 534 00:29:33.390 --> 00:29:34.590 Have they been tested? 535 00:29:36.660 --> 00:29:38.100 Yes, many of them have. 536 00:29:39.940 --> 00:29:41.040 Which ones have not? 537 00:29:44.210 --> 00:29:45.970 All of these actually have been executed. 538 00:29:45.970 --> 00:29:47.720 They were all executed in the fall. 539 00:29:49.520 --> 00:29:52.020 Yes, however, there were some failures in that execution. 540 00:29:52.020 --> 00:29:54.190 So you have not retested? 541 00:29:55.920 --> 00:29:58.260 We recognize, given the scale of the events 542 00:29:58.260 --> 00:30:00.570 that occurred in the fall of 2018, 543 00:30:00.570 --> 00:30:01.970 that there were improvements 544 00:30:01.970 --> 00:30:04.050 that we could make to the overall process. 545 00:30:04.050 --> 00:30:07.620 And we are working now to stand up those improvements 546 00:30:07.620 --> 00:30:10.020 so that in execution in 2020 going forward 547 00:30:11.378 --> 00:30:14.640 we will be better, smarter and faster at them. 548 00:30:14.640 --> 00:30:17.850 Okay, at line 28 you include the phrase, as possible. 549 00:30:17.850 --> 00:30:18.760 Do you see that? 550 00:30:18.760 --> 00:30:19.593 On which page? 551 00:30:22.270 --> 00:30:25.240 6-12, line 28. 552 00:30:25.240 --> 00:30:26.073 Um-hum. 553 00:30:27.230 --> 00:30:28.980 What do you mean by, as possible? 554 00:30:30.460 --> 00:30:32.690 Given the dynamic nature of weather, 555 00:30:32.690 --> 00:30:35.770 which is what's driving PSPS events, 556 00:30:35.770 --> 00:30:38.730 we are reliant on the weather forecast 557 00:30:38.730 --> 00:30:40.980 and the timeliness of those when they change, 558 00:30:42.130 --> 00:30:45.220 dictating when we are able to both scope the event 559 00:30:45.220 --> 00:30:47.670 and then convey that information accordingly 560 00:30:47.670 --> 00:30:48.670 to our stakeholders. 561 00:30:49.980 --> 00:30:52.780 So does this still mean that a customer could lose power 562 00:30:52.780 --> 00:30:55.550 with actually no notice during a PSPS event? 563 00:30:57.840 --> 00:30:59.530 There is the potential. 564 00:30:59.530 --> 00:31:02.630 While PG&E strives to ensure that we are able 565 00:31:02.630 --> 00:31:06.030 to quickly analyze any forecast changes 566 00:31:06.030 --> 00:31:07.650 and how that translates to the system 567 00:31:07.650 --> 00:31:10.050 and therefore to the customers affected, 568 00:31:10.050 --> 00:31:12.220 do that analysis as quickly as possible 569 00:31:12.220 --> 00:31:14.560 and execute on notifications accordingly. 570 00:31:15.810 --> 00:31:18.260 Weather is a very dynamic system. 571 00:31:18.260 --> 00:31:20.100 And if there are sudden changes, 572 00:31:20.100 --> 00:31:24.220 there could be the potential that we would potentially 573 00:31:24.220 --> 00:31:27.930 have a scope change and not be able to notify in advance. 574 00:31:27.930 --> 00:31:29.910 Priority of the program is to mitigate 575 00:31:29.910 --> 00:31:33.210 catastrophic fire risk while minimizing 576 00:31:33.210 --> 00:31:36.190 the public safety risk of de-energization. 577 00:31:36.190 --> 00:31:38.320 We feel that notification is key to that. 578 00:31:38.320 --> 00:31:41.430 So we'll always strive to do that as possible. 579 00:31:41.430 --> 00:31:44.840 One last question, you've mentioned weather 580 00:31:44.840 --> 00:31:48.470 as being the factor that would implicate whether 581 00:31:48.470 --> 00:31:50.260 or not customers get notice. 582 00:31:50.260 --> 00:31:52.650 Is there any other possible factor that might result 583 00:31:52.650 --> 00:31:56.060 in a customer not getting notice of being shutoff by PG&E? 584 00:31:59.110 --> 00:32:02.940 Scoping of the PSPS event is complex, so yes, 585 00:32:02.940 --> 00:32:04.790 The timeliness of weather forecasts 586 00:32:04.790 --> 00:32:08.498 and how often they change and how dynamic they are 587 00:32:08.498 --> 00:32:09.990 is certainly one major factor. 588 00:32:09.990 --> 00:32:12.640 The other is in our execution processes. 589 00:32:12.640 --> 00:32:14.760 So I mentioned that there were lessons learned 590 00:32:14.760 --> 00:32:18.390 in the fall events that we realized we can work to improve, 591 00:32:18.390 --> 00:32:21.740 automate some of the aspects of our scoping process 592 00:32:21.740 --> 00:32:24.080 to improve them and make them a bit more timely. 593 00:32:25.860 --> 00:32:27.260 So weather and automation? 594 00:32:28.280 --> 00:32:30.600 Weather, our scoping process 595 00:32:30.600 --> 00:32:32.910 and our notification process, yes. 596 00:32:32.910 --> 00:32:33.743 Thank you. 597 00:32:33.743 --> 00:32:34.576 Thank you, Your Honor. 598 00:32:34.576 --> 00:32:35.520 I appreciate your indulgence. 599 00:32:35.520 --> 00:32:37.220 I have no further questions. 600 00:32:37.220 --> 00:32:38.880 Thank you, Ms. Sheriff. 601 00:32:40.960 --> 00:32:42.162 Mr. Long. 602 00:32:42.162 --> 00:32:43.260 Thank you. 603 00:32:43.260 --> 00:32:44.660 Use the microphone, please. 604 00:32:52.160 --> 00:32:52.993 Good afternoon. 605 00:32:52.993 --> 00:32:54.160 I'm Tom Long with TURN. 606 00:32:54.160 --> 00:32:56.800 Ms. Powell, I think it's your turn for questions. 607 00:32:59.810 --> 00:33:01.860 If I could, can I just clarify, 608 00:33:01.860 --> 00:33:04.490 are questions being directed to individual witnesses 609 00:33:04.490 --> 00:33:05.610 or the panel as a whole? 610 00:33:05.610 --> 00:33:07.747 I thought Your Honor said the panel as a whole. 611 00:33:07.747 --> 00:33:09.847 Well, they can be either way 612 00:33:10.946 --> 00:33:12.850 I think if you know what the specific witness is. 613 00:33:12.850 --> 00:33:15.230 Given that PG&E has identified specific witnesses 614 00:33:15.230 --> 00:33:17.930 for specific sections, if there's questions 615 00:33:17.930 --> 00:33:20.660 that are aimed specifically at that section, 616 00:33:20.660 --> 00:33:22.640 it's fine to identify one. 617 00:33:22.640 --> 00:33:25.090 If one of the other witnesses wishes 618 00:33:25.090 --> 00:33:28.280 to add on to that or wishes to respond, 619 00:33:28.280 --> 00:33:30.200 that witness can do that. 620 00:33:30.200 --> 00:33:31.980 Thank you, Your Honor. 621 00:33:31.980 --> 00:33:33.540 The reason I identified Ms. Powell was 622 00:33:33.540 --> 00:33:34.650 because I'm asking questions 623 00:33:34.650 --> 00:33:37.150 about the section that she has sponsored. 624 00:33:38.970 --> 00:33:42.590 Ms. Powell, in particular I'd like to ask some questions 625 00:33:42.590 --> 00:33:45.130 about the section C, which is headed, 626 00:33:45.130 --> 00:33:47.860 Organizational Structure and Governance. 627 00:33:47.860 --> 00:33:51.700 And on pages 6-2 and 6-3 there to identify a number 628 00:33:51.700 --> 00:33:53.350 of organizations that have a role 629 00:33:54.320 --> 00:33:56.700 in wildfire safety, is that correct? 630 00:33:57.880 --> 00:33:58.780 That is correct. 631 00:33:59.774 --> 00:34:03.930 And I hope you have with you the response 632 00:34:03.930 --> 00:34:08.780 to TURN Data Request 17-3 and the attachment, 633 00:34:08.780 --> 00:34:11.960 which has been marked as Cross-Examination Exhibit X-02. 634 00:34:11.960 --> 00:34:13.210 I asked your counsel to make sure 635 00:34:13.210 --> 00:34:14.860 that you were supplied with that. 636 00:34:18.440 --> 00:34:20.530 I believe I have that in front of me, 637 00:34:20.530 --> 00:34:23.330 which includes a whole bunch of organization charts. 638 00:34:23.330 --> 00:34:24.380 Yes. 639 00:34:24.380 --> 00:34:27.817 Okay, so 17-3 the question identified 640 00:34:31.240 --> 00:34:33.090 that same part C we just looked at. 641 00:34:34.070 --> 00:34:36.220 And said, asked to provide an organization chart 642 00:34:36.220 --> 00:34:38.670 that shows the responsibilities and reporting relationships 643 00:34:38.670 --> 00:34:41.590 of the positions, organizations, et cetera. 644 00:34:41.590 --> 00:34:42.470 I'm sorry I'm not-- 645 00:34:42.470 --> 00:34:43.770 Okay, sure, be happy to. 646 00:34:46.040 --> 00:34:46.873 Starting over. 647 00:34:46.873 --> 00:34:51.873 That question asked you to provide an organization chart 648 00:34:52.050 --> 00:34:55.590 that shows responsibilities and reporting relationships 649 00:34:55.590 --> 00:34:58.140 of those various organizations mentioned in part C. 650 00:34:58.140 --> 00:34:58.973 Do you see that? 651 00:35:03.832 --> 00:35:04.700 Are you on page three, question three? 652 00:35:04.700 --> 00:35:05.790 That's right. 653 00:35:05.790 --> 00:35:06.860 Yes, I see that. 654 00:35:06.860 --> 00:35:09.830 Okay and then the response was 655 00:35:09.830 --> 00:35:11.590 to supply the organization chart 656 00:35:11.590 --> 00:35:15.380 that is attached to this exhibit; is that right? 657 00:35:15.380 --> 00:35:16.330 Correct. Okay. 658 00:35:20.330 --> 00:35:24.630 Beginning with your organization, I believe 659 00:35:24.630 --> 00:35:29.630 that's shown on page 622 of this organization chart. 660 00:35:37.150 --> 00:35:38.500 You're one of the boxes 661 00:35:38.500 --> 00:35:41.480 underneath the Senior Vice President, Mr. Lewis. 662 00:35:42.660 --> 00:35:44.260 I'm not on page, correct. 663 00:35:52.020 --> 00:35:54.490 Okay, so there's that box to the far right 664 00:35:55.510 --> 00:35:58.820 that says CWSP and Asset Risk Management, 665 00:35:58.820 --> 00:36:00.410 that's your organization? 666 00:36:00.410 --> 00:36:01.280 It is. Okay. 667 00:36:02.640 --> 00:36:06.130 Now, is your organization responsible for all 668 00:36:06.130 --> 00:36:09.560 of the programs in PG&E's Wildfire Mitigation Plan? 669 00:36:12.240 --> 00:36:13.073 It is not. 670 00:36:14.380 --> 00:36:17.460 Which organizations, I'm sorry, 671 00:36:17.460 --> 00:36:19.910 which programs in the Wildfire Mitigation Plan 672 00:36:21.600 --> 00:36:23.480 are not covered by your organization? 673 00:36:26.360 --> 00:36:28.010 This may take a couple minutes. 674 00:36:29.910 --> 00:36:34.910 So we are organized today in a plan, do, check, 675 00:36:35.040 --> 00:36:39.820 kind of organization structure within electric operations. 676 00:36:39.820 --> 00:36:44.820 My organization has the planning aspects of our work, 677 00:36:45.430 --> 00:36:48.700 ensuring that the work plan for the year is identified, 678 00:36:48.700 --> 00:36:51.390 the appropriate resources are identified for 679 00:36:51.390 --> 00:36:52.400 that work to occur. 680 00:36:53.630 --> 00:36:57.520 We've been spending quite a bit of time here today talking 681 00:36:57.520 --> 00:37:02.520 about the vegetation management aspects of our program. 682 00:37:02.690 --> 00:37:05.470 And the Vegetation Management Program 683 00:37:05.470 --> 00:37:08.660 is within Ahmad Ababneh's organization, 684 00:37:08.660 --> 00:37:12.010 which is the Major Projects and Programs. 685 00:37:13.810 --> 00:37:17.930 His organization also has the key inspections 686 00:37:17.930 --> 00:37:20.410 that are done of our assets. 687 00:37:22.790 --> 00:37:27.790 In the performance of work for repairs, that work, 688 00:37:29.610 --> 00:37:33.290 whether it's transmission or distribution 689 00:37:33.290 --> 00:37:36.810 are performed by either Tom French's organization 690 00:37:36.810 --> 00:37:38.610 or Ken Wells's organization. 691 00:37:38.610 --> 00:37:41.420 So we have separate organizations identifying the work 692 00:37:41.420 --> 00:37:43.730 to be performed as the organizations 693 00:37:43.730 --> 00:37:46.390 who are actually performing the work. 694 00:37:46.390 --> 00:37:50.170 And then the check piece in Lisa Jordan's organization 695 00:37:50.170 --> 00:37:53.910 is where we have a quality assurance process 696 00:37:53.910 --> 00:37:56.150 to go back through and make sure 697 00:37:56.150 --> 00:37:58.450 that we validated the work has been performed. 698 00:38:00.960 --> 00:38:02.170 Okay and I think you used the term 699 00:38:02.170 --> 00:38:04.480 at the beginning of your answer. 700 00:38:04.480 --> 00:38:07.290 Was it plan, do, check? 701 00:38:07.290 --> 00:38:08.123 Correct. 702 00:38:08.123 --> 00:38:12.900 Okay, where does your organization fit into that scheme? 703 00:38:16.050 --> 00:38:18.500 My organization has the plan function. 704 00:38:19.460 --> 00:38:24.410 And planning for the Wildfire Mitigation Plan Programs? 705 00:38:29.140 --> 00:38:31.500 It's an interesting way to ask the question. 706 00:38:31.500 --> 00:38:35.830 So last year putting together 707 00:38:35.830 --> 00:38:40.830 the Wildfire Mitigation Plan Programs was done in response, 708 00:38:43.780 --> 00:38:47.550 a very heightened effort that we pulled 709 00:38:47.550 --> 00:38:51.100 a whole organization together to respond to. 710 00:38:51.100 --> 00:38:54.060 And that was a separate effort from the rest 711 00:38:54.060 --> 00:38:57.793 of the work that was performed by the organization. 712 00:38:57.793 --> 00:39:01.930 It was essentially a mini emergency operations center 713 00:39:01.930 --> 00:39:05.710 that was in play for the, essentially the entire year. 714 00:39:06.920 --> 00:39:10.000 When electric operations organized, 715 00:39:10.000 --> 00:39:13.830 they reorganized at the end of 2019 recognizing 716 00:39:13.830 --> 00:39:15.600 that the level of effort that we had 717 00:39:15.600 --> 00:39:18.860 in '19 would not be sustainable 718 00:39:18.860 --> 00:39:23.350 nor affordable for a long-term view. 719 00:39:23.350 --> 00:39:26.650 We took those emergent functions 720 00:39:26.650 --> 00:39:30.310 and then we embedded them into the organization 721 00:39:30.310 --> 00:39:34.110 and the organizations under the plan, do, check function. 722 00:39:34.110 --> 00:39:39.110 So my organization performs the planning for all of the work 723 00:39:39.230 --> 00:39:42.020 that is completed within electric operations. 724 00:39:47.556 --> 00:39:48.389 Do you do planning work 725 00:39:48.389 --> 00:39:50.780 for enhanced vegetation management? 726 00:39:54.850 --> 00:39:59.850 We identify the priority miles based on risk 727 00:40:00.700 --> 00:40:04.840 that are required to have work performed. 728 00:40:04.840 --> 00:40:09.090 And then that work package is handed off 729 00:40:09.090 --> 00:40:14.090 to the Major Projects and Programs Organization 730 00:40:14.480 --> 00:40:16.090 for execution. 731 00:40:16.090 --> 00:40:19.530 So is it fair to say that you're the plan part 732 00:40:19.530 --> 00:40:21.550 of the EVM work? 733 00:40:21.550 --> 00:40:22.383 Correct. 734 00:40:27.620 --> 00:40:29.440 And would that be the case also for say, 735 00:40:29.440 --> 00:40:31.950 the Wildfire Safety Inspection Program? 736 00:40:31.950 --> 00:40:33.800 You're the plan part of that program? 737 00:40:34.810 --> 00:40:37.000 So that's where it gets fun. 738 00:40:37.000 --> 00:40:41.560 The Wildfire Safety Inspection Program as we had it dubbed 739 00:40:41.560 --> 00:40:45.360 in 2019 has now been incorporated 740 00:40:45.360 --> 00:40:47.350 into our regular work processes. 741 00:40:47.350 --> 00:40:50.540 So it's no longer a standalone program. 742 00:41:02.510 --> 00:41:06.260 But there's someone that, so there's nobody that does, 743 00:41:06.260 --> 00:41:09.100 that's not a plan, do, check kind of program then, 744 00:41:09.100 --> 00:41:09.933 is that right? 745 00:41:11.230 --> 00:41:13.390 The components of work that were part 746 00:41:13.390 --> 00:41:15.350 of the WISP are incorporated 747 00:41:15.350 --> 00:41:17.820 into our plan, do, check, function. 748 00:41:17.820 --> 00:41:22.740 So the WISP inspections were the detailed inspections 749 00:41:22.740 --> 00:41:24.550 of our equipment. 750 00:41:24.550 --> 00:41:28.030 And we last year inspected nearly everything, 751 00:41:28.030 --> 00:41:31.650 I think everything in our Tier Two and Tier Three zones. 752 00:41:31.650 --> 00:41:35.160 And this year we've committed to 100% of the assets 753 00:41:35.160 --> 00:41:38.300 in the Tier Three areas, 1/3 of our assets 754 00:41:38.300 --> 00:41:43.060 in the Tier Two areas and then keeping our Tier One areas 755 00:41:43.060 --> 00:41:45.020 on a five-year plan. 756 00:41:45.020 --> 00:41:48.690 That formulates into a specific work plan 757 00:41:48.690 --> 00:41:52.020 that is executed on in the major programs, 758 00:41:52.020 --> 00:41:53.440 project and programs area. 759 00:41:55.660 --> 00:41:57.882 So if I'm understanding you, 760 00:41:57.882 --> 00:42:00.270 your organization does not have responsibility anymore 761 00:42:00.270 --> 00:42:04.000 for Wildfire Safety Inspection Program, is that right? 762 00:42:11.580 --> 00:42:14.990 I would say we have the responsibility for planning 763 00:42:14.990 --> 00:42:16.590 that the work is going to occur. 764 00:42:17.710 --> 00:42:20.790 And we also have the reporting responsibility 765 00:42:20.790 --> 00:42:22.500 of what work has been completed 766 00:42:22.500 --> 00:42:25.140 to the higher levels of the corporation. 767 00:42:36.980 --> 00:42:38.950 And sticking with that program, 768 00:42:38.950 --> 00:42:40.760 Wildfire Safety Inspection Program, 769 00:42:41.909 --> 00:42:45.310 I think you said that that's primarily work 770 00:42:46.540 --> 00:42:50.590 that comes under Major Project and Programs now, right? 771 00:42:50.590 --> 00:42:53.140 So the inspections are performed 772 00:42:53.140 --> 00:42:56.240 in the Major Projects and Programs Organization. 773 00:42:57.380 --> 00:43:01.650 Any repairs or work that is identified to be performed 774 00:43:01.650 --> 00:43:04.780 is performed in the Electric Transmission Operations 775 00:43:04.780 --> 00:43:08.390 through the Electric Distribution Operations Organizations. 776 00:43:09.880 --> 00:43:13.300 And so if we look at major, we're back on 622 777 00:43:13.300 --> 00:43:15.840 of the organization chart, page 622. 778 00:43:15.840 --> 00:43:16.720 Okay. 779 00:43:16.720 --> 00:43:21.720 It's third row, far left box, it's the Major Project 780 00:43:23.310 --> 00:43:25.640 and Programs Organization; correct? 781 00:43:25.640 --> 00:43:26.473 Correct. 782 00:43:26.473 --> 00:43:29.470 And that directs us to page 623, which is the next page, 783 00:43:34.950 --> 00:43:36.470 which boxes on that page 784 00:43:36.470 --> 00:43:40.900 would be Wildfire Safety Inspection Program boxes? 785 00:43:42.800 --> 00:43:45.260 Depending on how you consider 786 00:43:45.260 --> 00:43:46.940 the Wildfire Safety Inspection. 787 00:43:46.940 --> 00:43:49.540 If you're talking about our equipment 788 00:43:49.540 --> 00:43:52.890 and the specific equipment inspections that occur there? 789 00:43:52.890 --> 00:43:54.140 Yeah, let's start with transmission. 790 00:43:54.140 --> 00:43:56.240 Let's start doing transmission inspections. 791 00:43:56.240 --> 00:43:57.073 Which box? 792 00:43:59.200 --> 00:44:02.530 Transmission and distribution inspections are 793 00:44:02.530 --> 00:44:05.790 in the director of system inspections for the utility. 794 00:44:05.790 --> 00:44:08.020 That's line three, under Mary Hvistendahl. 795 00:44:10.330 --> 00:44:15.123 Okay, that's both transmission and distribution you say? 796 00:44:16.490 --> 00:44:17.323 Correct. 797 00:44:34.230 --> 00:44:38.563 Back on your testimony at page 6-3, line ome, 798 00:44:42.200 --> 00:44:43.130 talking about your team. 799 00:44:43.130 --> 00:44:47.270 You're saying your team is primarily responsible 800 00:44:47.270 --> 00:44:50.030 for engineering, fire prevention, et cetera. 801 00:44:51.040 --> 00:44:52.940 What do you mean by engineering there? 802 00:44:58.250 --> 00:45:00.130 So my organization has the, 803 00:45:02.340 --> 00:45:06.210 we have the asset management function for the organization. 804 00:45:06.210 --> 00:45:08.220 And as part of that asset management function 805 00:45:08.220 --> 00:45:11.030 of the organization, there are engineers 806 00:45:12.140 --> 00:45:15.670 in our team who perform risk analysis 807 00:45:15.670 --> 00:45:20.220 who understand the health of our equipment 808 00:45:20.220 --> 00:45:24.110 and formulate the plans for the work 809 00:45:24.110 --> 00:45:26.140 that gets performed on the equipment. 810 00:45:31.200 --> 00:45:36.200 Continuing on to line two, from line one to line two, 811 00:45:38.300 --> 00:45:40.700 you use the term fire prevention and mitigation. 812 00:45:41.940 --> 00:45:42.940 That's a broad term. 813 00:45:42.940 --> 00:45:46.800 What specifically is your group responsible for? 814 00:45:47.990 --> 00:45:52.990 So inside the organization we have protocols 815 00:45:56.442 --> 00:45:59.310 that we put in place during fire season 816 00:45:59.310 --> 00:46:03.320 that define processes whereby employees 817 00:46:03.320 --> 00:46:06.120 can actually perform work or are stood down 818 00:46:06.120 --> 00:46:10.630 from performing work based on the potential fire threat. 819 00:46:10.630 --> 00:46:13.740 It's based on weather and temperature conditions 820 00:46:13.740 --> 00:46:15.280 and dryness of fuels. 821 00:46:15.280 --> 00:46:18.550 So we have a procedure 822 00:46:18.550 --> 00:46:21.250 that governs how that work would be performed. 823 00:46:21.250 --> 00:46:24.930 We have crews whose function 824 00:46:24.930 --> 00:46:28.670 is for infrastructure protection 825 00:46:31.370 --> 00:46:34.710 and they have skills similar to firemen, 826 00:46:34.710 --> 00:46:36.550 but they are not actual firemen, 827 00:46:36.550 --> 00:46:40.460 but they do more infrastructure protection work for us. 828 00:46:45.120 --> 00:46:48.339 Going back to Wildfire Mitigation Plan Programs, 829 00:46:48.339 --> 00:46:53.339 where would find the responsible entity 830 00:46:56.410 --> 00:46:59.160 in your organization chart for Grid Hardening Programs? 831 00:47:02.700 --> 00:47:04.620 So for the Grid Hardening Programs, 832 00:47:04.620 --> 00:47:07.940 my team would identify the sections of grid 833 00:47:07.940 --> 00:47:09.680 that would require to be hardened. 834 00:47:11.010 --> 00:47:16.010 And those get turned over to the Major Projects and Programs 835 00:47:17.140 --> 00:47:19.140 for engineering and construction. 836 00:47:22.020 --> 00:47:25.100 Sometimes other crews would do that, 837 00:47:25.100 --> 00:47:27.840 but the majority of that work gets performed in MPMP. 838 00:47:35.887 --> 00:47:37.630 Okay, then last question that's a followup 839 00:47:37.630 --> 00:47:41.820 from the Center for Accessible Technologies' questions. 840 00:47:45.000 --> 00:47:50.000 This may be for you, Ms., which is: 841 00:47:51.610 --> 00:47:56.310 Who's responsible for keeping customers safe 842 00:47:56.310 --> 00:47:58.630 in PSPS events as best PG&E is able? 843 00:48:06.100 --> 00:48:10.050 PG&E strives to ensure the safety 844 00:48:10.050 --> 00:48:12.380 of the communities we serve during PSPS events 845 00:48:14.140 --> 00:48:15.920 largely through in advance of the season. 846 00:48:15.920 --> 00:48:18.180 Ensuring that they're aware of the potential of them, 847 00:48:18.180 --> 00:48:19.810 the preparedness efforts that they can 848 00:48:19.810 --> 00:48:22.800 and should be taking and then during events 849 00:48:22.800 --> 00:48:24.910 through our notification directly 850 00:48:24.910 --> 00:48:29.460 to customers with the potential of being affected. 851 00:48:29.460 --> 00:48:30.630 Okay, I understand that, but again, 852 00:48:30.630 --> 00:48:33.630 it's a question of accountability and responsibility. 853 00:48:33.630 --> 00:48:37.090 Is that your organization that has that responsibility? 854 00:48:37.090 --> 00:48:39.290 My organization has built the processes 855 00:48:39.290 --> 00:48:42.160 and procedures in place for executing an event. 856 00:48:42.160 --> 00:48:45.850 And that includes notification to affected customers. 857 00:48:47.670 --> 00:48:50.660 The safety of our communities I think is a joint 858 00:48:50.660 --> 00:48:54.490 and shared responsibility across many organizations 859 00:48:54.490 --> 00:48:57.780 from state to city and county officials to first responders. 860 00:48:57.780 --> 00:48:59.160 This is a lot of words, but really, 861 00:48:59.160 --> 00:49:01.120 my question's quite simple. 862 00:49:01.120 --> 00:49:03.250 Which organization of PG&E 863 00:49:03.250 --> 00:49:05.520 is responsible for keeping customers safe 864 00:49:05.520 --> 00:49:09.500 in a PSPS event as best PG&E is able? 865 00:49:10.454 --> 00:49:11.287 Is that yours? 866 00:49:12.920 --> 00:49:15.300 In keeping them safe as much as we can 867 00:49:15.300 --> 00:49:18.270 through ensuring they're aware of the potential event, yes. 868 00:49:18.270 --> 00:49:22.290 That is within our PSPS organization executed through our, 869 00:49:22.290 --> 00:49:23.900 as I mentioned, during the EOC, 870 00:49:23.900 --> 00:49:28.710 our customer section within our Emergency Operation Center. 871 00:49:28.710 --> 00:49:29.720 Okay, thank you. 872 00:49:29.720 --> 00:49:31.070 That's all of my questions. 873 00:49:32.040 --> 00:49:32.910 Thank you Mr. Long. 874 00:49:32.910 --> 00:49:33.743 Mr. Alcantar. 875 00:49:45.870 --> 00:49:46.703 Good afternoon. 876 00:49:46.703 --> 00:49:47.536 My name is Michael Alcantar. 877 00:49:47.536 --> 00:49:49.710 I represent the Energy Producers 878 00:49:49.710 --> 00:49:52.080 and Users Coalition in this proceeding 879 00:49:52.080 --> 00:49:53.890 as well for the purposes 880 00:49:53.890 --> 00:49:55.990 of this proceeding the Indicated Shippers. 881 00:49:59.067 --> 00:50:01.840 Ms. Powell, I would like to explore with you the paragraph 882 00:50:01.840 --> 00:50:04.760 that is on page one of your testimony, 883 00:50:04.760 --> 00:50:08.910 PG&E-01, it's 6-1, beginning at line 20. 884 00:50:10.190 --> 00:50:14.900 That paragraph introduces your exposure if you will, 885 00:50:14.900 --> 00:50:19.700 laughing, to your knowledge of AB 1054. 886 00:50:25.010 --> 00:50:28.050 You agree do you not that AB 1054 provides 887 00:50:28.050 --> 00:50:31.930 for certain protections for ratepayers from costs 888 00:50:31.930 --> 00:50:34.110 that may be incurred by PG&E associated 889 00:50:34.110 --> 00:50:38.100 with wildfire liabilities and bankruptcy exposure? 890 00:50:39.440 --> 00:50:40.930 Object, it's lacking foundation. 891 00:50:40.930 --> 00:50:42.350 Calling for legal conclusion. 892 00:50:42.350 --> 00:50:43.183 Overruled. 893 00:50:43.183 --> 00:50:44.490 She can answer if she knows. 894 00:50:48.600 --> 00:50:50.520 I don't have a legal background. 895 00:50:50.520 --> 00:50:51.600 I'm not asking for-- And although-- 896 00:50:51.600 --> 00:50:54.200 I'm asking for what your stated understanding 897 00:50:54.200 --> 00:50:55.800 is right here in your testimony. 898 00:50:57.120 --> 00:51:02.120 Although what I know and have heard about AB 1054, 899 00:51:02.240 --> 00:51:04.910 what I have heard is that the company 900 00:51:04.910 --> 00:51:08.567 will not negatively impact our customers 901 00:51:13.940 --> 00:51:15.240 through these proceedings. 902 00:51:17.680 --> 00:51:19.150 Do you know the term baseline 903 00:51:19.150 --> 00:51:23.090 as it's referred to in AB 1054? 904 00:51:23.090 --> 00:51:23.923 I do not. 905 00:51:26.600 --> 00:51:29.040 You're not aware of which costs, 906 00:51:29.040 --> 00:51:31.360 but just generally there are some costs 907 00:51:31.360 --> 00:51:35.910 that this statutory protection applies for ratepayers; 908 00:51:35.910 --> 00:51:37.160 is that a fair statement? 909 00:51:38.260 --> 00:51:39.093 It is. 910 00:51:42.014 --> 00:51:44.460 Do you have any question that the Commission 911 00:51:44.460 --> 00:51:47.650 will determine whether or not actions 912 00:51:47.650 --> 00:51:52.600 that are undertaken by your organization are deemed just, 913 00:51:52.600 --> 00:51:54.750 reasonable and recoverable from ratepayers? 914 00:52:01.030 --> 00:52:05.850 I am aware that there are proceedings for recovery 915 00:52:05.850 --> 00:52:08.320 of costs associated with some of the work 916 00:52:08.320 --> 00:52:11.100 that we perform that do enter 917 00:52:11.100 --> 00:52:14.080 into a separate proceeding of the CPUC. 918 00:52:14.080 --> 00:52:18.030 Beyond that high-level snippet of knowledge, 919 00:52:18.030 --> 00:52:19.630 I do not have the details. 920 00:52:20.810 --> 00:52:23.410 So what do you think this proceeding 921 00:52:23.410 --> 00:52:28.410 is about with respect to the recovery of such costs? 922 00:52:33.210 --> 00:52:34.652 I think that's outside the scope 923 00:52:34.652 --> 00:52:36.960 of my chapter of testimony. 924 00:52:39.680 --> 00:52:44.660 So this is the level of your understanding, that alone. 925 00:52:46.680 --> 00:52:48.980 Do you have a spreadsheet, or are you aware 926 00:52:48.980 --> 00:52:51.730 of any information that's been provided 927 00:52:51.730 --> 00:52:54.580 in this record by you or others 928 00:52:54.580 --> 00:52:56.500 that would identify the total cost 929 00:52:56.500 --> 00:52:59.403 for the programs you're overseeing 930 00:52:59.403 --> 00:53:00.890 with respect to wildfire plans? 931 00:53:03.390 --> 00:53:05.980 I have not specifically seen a spreadsheet 932 00:53:05.980 --> 00:53:07.230 regarding those costs. 933 00:53:10.500 --> 00:53:12.970 Do you know what total costs PG&E has expended 934 00:53:12.970 --> 00:53:15.350 for the programs you're overseeing to date 935 00:53:16.250 --> 00:53:17.800 that it will seek recovery for? 936 00:53:19.250 --> 00:53:21.000 I don't have a breakdown of that. 937 00:53:21.910 --> 00:53:24.210 Do you have a round figure about what it is? 938 00:53:25.150 --> 00:53:27.560 I don't know the 2019 costs. 939 00:53:27.560 --> 00:53:31.050 I know the costs of implementation for our work 940 00:53:31.050 --> 00:53:34.510 in 2020 what they are projected to be. 941 00:53:34.510 --> 00:53:35.870 Okay, what is that? 942 00:53:35.870 --> 00:53:38.660 It's projected to be about 3.2 billion dollars. 943 00:53:50.220 --> 00:53:51.820 You've used the term a few times 944 00:53:51.820 --> 00:53:54.680 in your testimony, the term, repairs. 945 00:53:55.640 --> 00:53:58.660 Can you distinguish repairs from hardening? 946 00:54:03.680 --> 00:54:04.513 I can. 947 00:54:05.540 --> 00:54:10.540 So when you think about repairs of a piece of equipment, 948 00:54:11.110 --> 00:54:12.670 take your car. 949 00:54:13.990 --> 00:54:15.090 Do you have a vehicle? 950 00:54:17.880 --> 00:54:20.390 I do have a vehicle, yes, I have a few of them. 951 00:54:20.390 --> 00:54:25.390 Okay and so when your car gives you a warning light 952 00:54:27.450 --> 00:54:32.070 that tells you it needs to go in and be repaired, 953 00:54:32.070 --> 00:54:33.580 you do that generally, right? 954 00:54:34.460 --> 00:54:36.810 Let's make sure that Mr. Alcantar 955 00:54:36.810 --> 00:54:38.028 is asking the questions. 956 00:54:38.028 --> 00:54:39.940 (laughing) 957 00:54:39.940 --> 00:54:42.780 I'm sorry, I'm trying to explain in sort of lay terms. 958 00:54:42.780 --> 00:54:44.380 I assume that Mr. Alcantar understands 959 00:54:44.380 --> 00:54:45.620 how his car works. 960 00:54:45.620 --> 00:54:46.870 Okay, good. 961 00:54:46.870 --> 00:54:50.660 So same thing with our assets. 962 00:54:51.590 --> 00:54:53.490 We inspect them. 963 00:54:53.490 --> 00:54:56.800 When we inspect them, that we identify conditions 964 00:54:56.800 --> 00:55:00.490 that require something to be done about them. 965 00:55:00.490 --> 00:55:02.670 And we schedule and perform that work. 966 00:55:02.670 --> 00:55:05.070 That's what I consider a repair. 967 00:55:05.070 --> 00:55:07.540 When you think about system hardening, 968 00:55:08.490 --> 00:55:11.520 system hardening is whether we're putting 969 00:55:11.520 --> 00:55:16.270 in composite poles; whether we're putting 970 00:55:16.270 --> 00:55:19.760 in wires that have an insulating material 971 00:55:19.760 --> 00:55:24.760 on the outside so that there can't be vegetation contact 972 00:55:25.310 --> 00:55:28.570 with them that might spark some kind of interaction. 973 00:55:28.570 --> 00:55:29.940 Those are the kinds of things 974 00:55:29.940 --> 00:55:33.500 where even undergrounding our infrastructure are items 975 00:55:33.500 --> 00:55:35.390 that are considered hardening. 976 00:55:35.390 --> 00:55:37.570 So let me give you a non-car analogy back. 977 00:55:37.570 --> 00:55:41.510 Let's assume I'm PG&E and I'm operating a grid 978 00:55:41.510 --> 00:55:44.970 and I happen to serve the area 979 00:55:44.970 --> 00:55:47.530 that is commonly now referred to as Paradise. 980 00:55:48.780 --> 00:55:51.410 And I have equipment there that has failed, if you will, 981 00:55:51.410 --> 00:55:53.070 I ran my car over somebody. 982 00:55:55.020 --> 00:55:57.600 And now I'm seeking recovery of costs 983 00:55:57.600 --> 00:56:01.140 to repair the transmission towers, repair 984 00:56:01.140 --> 00:56:06.080 and replace the transmission towers, the type of wiring, 985 00:56:06.080 --> 00:56:07.640 the system that was there 986 00:56:07.640 --> 00:56:12.350 that caused the catastrophic damage. 987 00:56:13.260 --> 00:56:17.420 Is that a grid-hardening expense that you expect to recover? 988 00:56:17.420 --> 00:56:19.610 Or is that a repair liability 989 00:56:19.610 --> 00:56:21.740 that you as PG&E shareholders will bear? 990 00:56:23.901 --> 00:56:25.550 I have to be perfectly honest, 991 00:56:25.550 --> 00:56:28.570 I do not know the cost treatment 992 00:56:29.550 --> 00:56:32.310 of the infrastructure work being performed 993 00:56:32.310 --> 00:56:33.430 in the Paradise area. 994 00:56:38.550 --> 00:56:41.910 Well, would it help you if it was not the Paradise area? 995 00:56:41.910 --> 00:56:45.160 Let's just assume it's a PG&E piece of equipment 996 00:56:45.160 --> 00:56:49.400 that causes injury to someone or something, 997 00:56:50.300 --> 00:56:52.640 and it needs to be repaired. 998 00:56:52.640 --> 00:56:57.640 Is that a cost that you would classify as grid hardening 999 00:56:59.060 --> 00:57:02.660 and subject to potential recovery from ratepayers? 1000 00:57:02.660 --> 00:57:06.220 Or as a repair for liabilities 1001 00:57:06.220 --> 00:57:08.880 that PG&E has for its shareholders? 1002 00:57:10.800 --> 00:57:14.560 When we have equipment repair that is necessary, 1003 00:57:15.960 --> 00:57:20.960 those items are typically funded through our rate case. 1004 00:57:22.040 --> 00:57:23.080 That's what I'm asking you, 1005 00:57:23.080 --> 00:57:26.120 a distinction between what's typical. 1006 00:57:26.120 --> 00:57:29.090 I don't think it's typical that we start wildfires. 1007 00:57:30.830 --> 00:57:34.540 So you have a repair that you must fulfill, 1008 00:57:35.420 --> 00:57:38.490 make no distinction between grid hardening 1009 00:57:38.490 --> 00:57:41.800 and repair recovery in those circumstances is, 1010 00:57:41.800 --> 00:57:44.390 I think, what I'm hearing from your testimony, is that fair? 1011 00:57:46.910 --> 00:57:50.330 I'm not sure I have the financial background 1012 00:57:50.330 --> 00:57:53.400 to make a determination to answer your question. 1013 00:57:57.380 --> 00:58:00.640 Your Honor, given the responses to those questions, 1014 00:58:00.640 --> 00:58:02.860 I have nothing further. 1015 00:58:02.860 --> 00:58:04.610 Thank you, Mr. Alcantar. 1016 00:58:07.200 --> 00:58:09.280 Mr. Strauss, did you have some questions? 1017 00:58:10.920 --> 00:58:12.370 Yes, Your Honor, thank you. 1018 00:58:13.540 --> 00:58:15.580 My name is Ariel Strauss. 1019 00:58:15.580 --> 00:58:17.260 I'm here on behalf of SBUA, 1020 00:58:18.410 --> 00:58:21.700 Small Business Utility Advocates. 1021 00:58:26.070 --> 00:58:28.330 I have a question for the panel, 1022 00:58:28.330 --> 00:58:30.370 because I don't know the best person 1023 00:58:30.370 --> 00:58:33.410 to direct this question to and that question 1024 00:58:33.410 --> 00:58:38.410 is regarding the overall price tag to the public 1025 00:58:38.530 --> 00:58:43.500 for the 2019 PSPS de-energization events. 1026 00:58:44.429 --> 00:58:46.930 Does PG&E have a calculation 1027 00:58:46.930 --> 00:58:50.530 for the overall impact to the public of those events? 1028 00:58:54.400 --> 00:58:55.790 I can answer. 1029 00:58:55.790 --> 00:58:59.570 No, PG&E does not have a calculation 1030 00:58:59.570 --> 00:59:02.060 of estimated cost to the public. 1031 00:59:02.060 --> 00:59:03.540 Thank you. 1032 00:59:03.540 --> 00:59:08.540 Previously the holding company CEO testified 1033 00:59:09.820 --> 00:59:14.000 that he expects that the need for PSPS events 1034 00:59:14.000 --> 00:59:16.470 could be eliminated in the coming 10 years. 1035 00:59:17.920 --> 00:59:22.250 I understand that means that certain work could be done 1036 00:59:22.250 --> 00:59:23.880 to the infrastructure that would eliminate 1037 00:59:23.880 --> 00:59:27.220 the need for PSPS events, is that correct? 1038 00:59:27.220 --> 00:59:30.040 Object as misscharacterizing the testimony. 1039 00:59:30.040 --> 00:59:30.970 Overruled. 1040 00:59:34.760 --> 00:59:39.140 So I'm not specifically aware of the exact language 1041 00:59:39.140 --> 00:59:44.140 that the CEO used in describing that projection. 1042 00:59:44.470 --> 00:59:47.000 I can say that PG&E is working diligently 1043 00:59:47.000 --> 00:59:51.440 to minimize the impacts of PSPS events going forward, 1044 00:59:51.440 --> 00:59:54.020 starting now working on asset-based solutions 1045 00:59:54.020 --> 00:59:59.020 to minimize the scope, frequency and duration. 1046 00:59:59.340 --> 01:00:01.530 So my question is without regard 1047 01:00:01.530 --> 01:00:03.530 to any previous testimony, 1048 01:00:03.530 --> 01:00:08.500 is it possible to eliminate the need for PSPS events 1049 01:00:08.500 --> 01:00:12.120 based on activity to be conducted and changes 1050 01:00:12.120 --> 01:00:14.410 to be made to the transmission 1051 01:00:14.410 --> 01:00:17.830 or other equipment that PG&E now holds? 1052 01:00:20.280 --> 01:00:22.080 I believe PG&E has an opportunity 1053 01:00:22.080 --> 01:00:25.340 to significantly reduce the impacts 1054 01:00:25.340 --> 01:00:28.190 and potential for PSPS events, 1055 01:00:28.190 --> 01:00:31.010 but the reality of it is these are weather-driven events 1056 01:00:31.010 --> 01:00:33.710 and we do not know the severity of weather 1057 01:00:33.710 --> 01:00:35.320 that will occur in the future 1058 01:00:35.320 --> 01:00:37.310 that could require de-energization. 1059 01:00:41.280 --> 01:00:45.327 Okay, Ms. Maratukulam, on page 6-13 1060 01:00:46.590 --> 01:00:50.570 of your testimony sponsored, 1061 01:00:50.570 --> 01:00:55.570 you state that for the 2020 wildfire season as a result 1062 01:00:56.510 --> 01:00:58.948 of leveraging more granular data 1063 01:00:58.948 --> 01:01:01.986 and deploying additional sectionalization devices. 1064 01:01:01.986 --> 01:01:03.210 (speaking off microphone) 1065 01:01:03.210 --> 01:01:07.380 Yes, for the 2020 wildfire season as a result 1066 01:01:07.380 --> 01:01:09.150 of leveraging more grandular data 1067 01:01:09.150 --> 01:01:12.370 and deploying additional sectionalization devices 1068 01:01:12.370 --> 01:01:16.260 field team pre-positioning microgrids and other activities, 1069 01:01:16.260 --> 01:01:18.860 the utility is targeting to reduce the number 1070 01:01:18.860 --> 01:01:22.340 of customers affected by individual PSPS events 1071 01:01:22.340 --> 01:01:23.610 by nearly 1/3. 1072 01:01:26.010 --> 01:01:31.010 Is this a fair representation to say that 1073 01:01:32.500 --> 01:01:37.500 that 1/3 target is based on a retrospective study of actions 1074 01:01:39.060 --> 01:01:42.110 that could have been taken to limit the effect 1075 01:01:42.110 --> 01:01:46.240 of October and November 2019 PSPS events? 1076 01:01:47.590 --> 01:01:50.170 That analysis was performed at the end 1077 01:01:50.170 --> 01:01:52.820 of the season looking back at our largest event, 1078 01:01:52.820 --> 01:01:55.780 October 26th, and the impact, scope, 1079 01:01:55.780 --> 01:01:58.300 and scale of that event specifically. 1080 01:01:58.300 --> 01:02:00.450 A case study was performed to evaluate 1081 01:02:00.450 --> 01:02:04.630 if we had various mitigation measures in place 1082 01:02:04.630 --> 01:02:06.210 and which are described there, 1083 01:02:06.210 --> 01:02:10.100 what would the potential reduction in customer impact be. 1084 01:02:10.100 --> 01:02:12.380 And from that case study specifically, 1085 01:02:12.380 --> 01:02:14.550 the 1/3 number was derived. 1086 01:02:14.550 --> 01:02:17.040 And will all those activities 1087 01:02:17.040 --> 01:02:20.730 that were identified be conducted in 2020 1088 01:02:20.730 --> 01:02:24.290 across all the areas in which PSPS events could occur? 1089 01:02:25.430 --> 01:02:28.210 Yes, so while the case study was performed 1090 01:02:28.210 --> 01:02:31.230 on the 10-26 event specifically. 1091 01:02:31.230 --> 01:02:34.790 We are working to operationalize those mitigation efforts 1092 01:02:34.790 --> 01:02:36.640 across the high-fire threat district. 1093 01:02:38.350 --> 01:02:40.770 And is it on target to be completed in 2020? 1094 01:02:43.930 --> 01:02:45.840 As Debbie alluded to, the execution 1095 01:02:45.840 --> 01:02:48.900 of a lot of this asset-based work is it sits 1096 01:02:48.900 --> 01:02:50.260 within other organizations 1097 01:02:50.260 --> 01:02:52.990 and I'm not familiar with their current work progress. 1098 01:02:54.380 --> 01:02:58.330 Would you then say that the target of a 1/3 reduction 1099 01:02:58.330 --> 01:03:00.010 in impacts or the number 1100 01:03:00.010 --> 01:03:02.310 of customers impacted is speculative? 1101 01:03:08.410 --> 01:03:11.080 It is based on that case study in particular, 1102 01:03:11.080 --> 01:03:14.440 so that 1/3 reduction would be reaped 1103 01:03:14.440 --> 01:03:18.600 if we had the same event occur in the same area. 1104 01:03:19.800 --> 01:03:21.020 Weather is dynamic. 1105 01:03:21.020 --> 01:03:22.920 We will see how this year plays out, 1106 01:03:22.920 --> 01:03:24.920 where it plays out and to what severity. 1107 01:03:25.930 --> 01:03:26.900 Thank you. 1108 01:03:26.900 --> 01:03:30.450 In response to Ms. Kasnitz's line of questioning, 1109 01:03:30.450 --> 01:03:32.660 Ms. Maratukulam, you confirmed you're aware 1110 01:03:32.660 --> 01:03:36.100 of public harms of the PSPS events. 1111 01:03:36.100 --> 01:03:38.460 Has PG&E assessed the risks of specific 1112 01:03:38.460 --> 01:03:41.880 negative public safety outcomes from PSPS events? 1113 01:03:44.140 --> 01:03:47.280 Broadly we look across our customer base 1114 01:03:47.280 --> 01:03:49.630 at the potential effects of de-energization 1115 01:03:49.630 --> 01:03:53.328 and are working with our customers to identify them 1116 01:03:53.328 --> 01:03:57.320 and ensure that preparedness efforts are put in place. 1117 01:03:58.210 --> 01:04:00.490 But with respect to specific events, 1118 01:04:00.490 --> 01:04:05.030 so let's say has PG&E been in touch with CHP 1119 01:04:05.030 --> 01:04:06.150 to identify whether there have been 1120 01:04:06.150 --> 01:04:09.350 more car accidents during PSPS events? 1121 01:04:11.540 --> 01:04:13.490 No, I don't believe that we have attempted 1122 01:04:13.490 --> 01:04:17.450 to quantify the effects from other agencies. 1123 01:04:17.450 --> 01:04:20.220 We are working to, we stood up a series 1124 01:04:20.220 --> 01:04:23.420 of listening sessions coming out of the fall events 1125 01:04:23.420 --> 01:04:26.050 to visit all of the affected cities and counties 1126 01:04:26.050 --> 01:04:28.230 and to hear from them feedback 1127 01:04:28.230 --> 01:04:31.080 of what they would like to see executed differently. 1128 01:04:31.080 --> 01:04:33.960 So, I would imagine, though I haven't seen the results 1129 01:04:33.960 --> 01:04:35.120 of those listening sessions, 1130 01:04:35.120 --> 01:04:37.450 that there was some feedback received 1131 01:04:37.450 --> 01:04:39.820 or input given in terms of effects. 1132 01:04:39.820 --> 01:04:41.560 Our goal with those listening sessions 1133 01:04:41.560 --> 01:04:43.810 is to learn how we can improve going forward. 1134 01:04:45.020 --> 01:04:47.440 And without that data, the specific data 1135 01:04:47.440 --> 01:04:51.190 on specific outcomes, how does PG&E determine 1136 01:04:51.190 --> 01:04:54.560 that the benefits of de-energization 1137 01:04:54.560 --> 01:04:56.650 outweigh potential public safety risks? 1138 01:04:59.560 --> 01:05:03.080 Each event is dynamic so we're working during the event 1139 01:05:03.080 --> 01:05:06.280 to reach out to local officials, 1140 01:05:06.280 --> 01:05:08.920 city and county agencies and first responders 1141 01:05:08.920 --> 01:05:12.190 to make them aware of the event and learn 1142 01:05:12.190 --> 01:05:14.490 of what the potential effects could be. 1143 01:05:14.490 --> 01:05:17.687 That is brought into our decision-making awareness 1144 01:05:17.687 --> 01:05:21.310 of what we are informed of as potential effects. 1145 01:05:21.310 --> 01:05:23.410 Did you just say, during the event? 1146 01:05:23.410 --> 01:05:24.320 Yes. 1147 01:05:24.320 --> 01:05:26.870 My question pertains to prior to the event 1148 01:05:26.870 --> 01:05:28.030 in terms of the decision-making 1149 01:05:28.030 --> 01:05:32.330 about whether de-energization will be initiated or not. 1150 01:05:32.330 --> 01:05:33.840 In advance of events, we're working 1151 01:05:33.840 --> 01:05:36.630 to mitigate those potential effects. 1152 01:05:36.630 --> 01:05:40.040 So when it comes down to making the actual decision, 1153 01:05:40.040 --> 01:05:42.410 we really do require that we have the scenario 1154 01:05:42.410 --> 01:05:45.340 in front of us to know what risks we have to balance. 1155 01:05:46.460 --> 01:05:47.293 Thank you. 1156 01:05:47.293 --> 01:05:48.960 That completes my questions, Your Honor. 1157 01:05:50.240 --> 01:05:51.220 Thank you. 1158 01:05:51.220 --> 01:05:55.590 I understand Mr. Abrams, any other cross? 1159 01:05:55.590 --> 01:05:57.470 Mr. Abrams, go ahead. 1160 01:05:57.470 --> 01:05:58.670 Thank you, Your Honor. 1161 01:05:59.870 --> 01:06:00.720 Thank you, panel. 1162 01:06:03.906 --> 01:06:05.130 I have some questions just following up 1163 01:06:05.130 --> 01:06:08.770 on some of the previous questions in this proceeding. 1164 01:06:09.660 --> 01:06:14.660 And specifically, Ms. Powell, you mentioned 1165 01:06:14.850 --> 01:06:19.850 sort of this plan, do, check differentiation. 1166 01:06:23.000 --> 01:06:28.000 And as I look through the testimony in this section, 1167 01:06:29.590 --> 01:06:34.590 one thing that struck me is that it's a description 1168 01:06:34.650 --> 01:06:38.580 of past activities or current activities. 1169 01:06:38.580 --> 01:06:41.220 Given that this is a Plan of Reorganization 1170 01:06:41.220 --> 01:06:44.430 and you are the head of that planning function, 1171 01:06:46.774 --> 01:06:49.310 I was expecting to see more planning 1172 01:06:49.310 --> 01:06:51.520 represented in the testimony. 1173 01:06:51.520 --> 01:06:56.520 Can you explain, please, why there wasn't more planning 1174 01:06:57.460 --> 01:06:59.230 and future and a discussion 1175 01:06:59.230 --> 01:07:02.810 about what's gonna happen going forward in the testimony? 1176 01:07:18.210 --> 01:07:22.540 When I think about the Chapter Six as part 1177 01:07:24.970 --> 01:07:29.970 of the Plan of the Reorganization and the concerns 1178 01:07:31.690 --> 01:07:36.690 in the state about wildfire mitigation 1179 01:07:37.220 --> 01:07:39.490 and Public Safety Power Shutoff, 1180 01:07:41.080 --> 01:07:46.080 we felt those topics and the plan of what we are doing, 1181 01:07:46.340 --> 01:07:49.470 which we referenced, the Wildfire Mitigation Plan, 1182 01:07:49.470 --> 01:07:53.370 which is a very large document describing 1183 01:07:53.370 --> 01:07:58.190 in a lot of detail the work that we're performing in 2020 1184 01:07:58.190 --> 01:08:03.190 and beyond to mitigate the potential effects of wildfire, 1185 01:08:05.300 --> 01:08:10.300 this seemed most relevant given the Plan of Reorganization. 1186 01:08:16.640 --> 01:08:21.640 So the bankruptcy and the Plan of Reorganization 1187 01:08:22.520 --> 01:08:26.450 is in response to, and the reason why PG&E is in bankruptcy, 1188 01:08:26.450 --> 01:08:31.450 is in response to a poor track record to this date. 1189 01:08:34.170 --> 01:08:39.170 And so part of what I imagine the Commission and parties 1190 01:08:39.850 --> 01:08:43.550 and the public are looking for is a course correction, 1191 01:08:43.550 --> 01:08:47.090 is a recognition of what's transpired in the past, 1192 01:08:47.090 --> 01:08:49.490 but a forward-looking view of here's what we're 1193 01:08:49.490 --> 01:08:52.860 gonna be doing differently going forward. 1194 01:08:52.860 --> 01:08:55.170 So what have you described in your testimony 1195 01:08:55.170 --> 01:08:59.560 in terms of the planning function in the testimony 1196 01:08:59.560 --> 01:09:02.250 that is different that will provide a level 1197 01:09:02.250 --> 01:09:05.700 of confidence that things will change moving forward? 1198 01:09:12.600 --> 01:09:16.330 I would refer you to the Wildfire Mitigation Plan, 1199 01:09:16.330 --> 01:09:18.910 which was filed, I think, about a week 1200 01:09:19.810 --> 01:09:22.800 after this testimony was filed. 1201 01:09:22.800 --> 01:09:27.610 The Wildfire Mitigation Plan has more than 200 pages 1202 01:09:27.610 --> 01:09:32.610 about what we are doing to mitigate that risk 1203 01:09:33.350 --> 01:09:38.350 and to implement additional items in 2020 1204 01:09:38.660 --> 01:09:41.770 and beyond to address the wildfire threat. 1205 01:09:48.560 --> 01:09:50.270 So how has that been incorporated 1206 01:09:50.270 --> 01:09:52.300 into the Plan of Reorganization, 1207 01:09:52.300 --> 01:09:57.300 which is the official organizational framework for how 1208 01:09:59.250 --> 01:10:02.290 that Wildfire Mitigation Plan is gonna be supported? 1209 01:10:02.290 --> 01:10:05.790 Where's the forward-looking, here's how we're gonna change 1210 01:10:05.790 --> 01:10:08.200 to address what you just described? 1211 01:10:11.800 --> 01:10:13.900 I'm not sure I understand your question. 1212 01:10:15.970 --> 01:10:20.970 So reorganization, restructuring, is a change in course. 1213 01:10:23.240 --> 01:10:25.740 Would you not say that that's a correct statement? 1214 01:10:30.260 --> 01:10:32.210 I'd agree that it's a plan 1215 01:10:32.210 --> 01:10:34.890 for how the company will move forward. 1216 01:10:35.920 --> 01:10:38.570 Okay, so not a change? 1217 01:10:39.680 --> 01:10:41.070 I didn't say that. 1218 01:10:41.070 --> 01:10:42.520 Well, I'm asking, it's a question. 1219 01:10:42.520 --> 01:10:44.200 It's a plan. Is that not a change? 1220 01:10:44.200 --> 01:10:46.310 Let's have one person talk at a time. 1221 01:10:46.310 --> 01:10:48.610 So go ahead, Mr. Abrams. 1222 01:10:50.120 --> 01:10:52.150 So you said it's a plan. 1223 01:10:52.150 --> 01:10:56.180 What I'm asking for is the Plan of Reorganization, 1224 01:10:56.180 --> 01:10:59.970 Plan of Restructuring, meant to be a change 1225 01:10:59.970 --> 01:11:01.620 in terms of how you move forward? 1226 01:11:04.580 --> 01:11:05.880 I could agree with that. 1227 01:11:07.870 --> 01:11:09.180 Do you? 1228 01:11:09.180 --> 01:11:11.200 I appreciate that. 1229 01:11:11.200 --> 01:11:12.350 Do you agree with that? 1230 01:11:15.470 --> 01:11:16.303 I do. 1231 01:11:17.162 --> 01:11:19.220 Okay, so given that you feel 1232 01:11:19.220 --> 01:11:22.070 like the Plan of Reorganization, the Plan of Restructuring 1233 01:11:22.070 --> 01:11:25.080 is a change in the path ahead, 1234 01:11:26.290 --> 01:11:29.350 where in your testimony do you describe 1235 01:11:29.350 --> 01:11:33.060 that change in the plan? 1236 01:11:33.960 --> 01:11:35.810 How are you doing things differently? 1237 01:11:39.710 --> 01:11:43.740 Let me just ask a question to clarify. 1238 01:11:43.740 --> 01:11:47.450 Ms. Powell, am I correct that none 1239 01:11:47.450 --> 01:11:51.620 of the wildfire safety measures in Chapter Six, 1240 01:11:51.620 --> 01:11:53.980 or their costs, are actually part 1241 01:11:53.980 --> 01:11:56.330 of the Plan of Reorganization, is that correct? 1242 01:12:00.960 --> 01:12:04.120 Our Plan of Reorganization is a financial plan 1243 01:12:05.000 --> 01:12:07.940 that includes the body of work 1244 01:12:07.940 --> 01:12:11.550 that is included in our Wildfire Mitigation Plan. 1245 01:12:13.650 --> 01:12:17.960 So the costs and measures in the Wildfire Mitigation Plan 1246 01:12:17.960 --> 01:12:22.410 or at least the costs of the Wildfire Mitigation Plan 1247 01:12:22.410 --> 01:12:24.240 are taken into account 1248 01:12:24.240 --> 01:12:26.230 in the Plan of Reorganization, correct? 1249 01:12:26.230 --> 01:12:27.170 Correct. 1250 01:12:27.170 --> 01:12:31.500 But the measures in either Chapter Six 1251 01:12:31.500 --> 01:12:33.960 or in the Wildfire Mitigation Plan are not part 1252 01:12:33.960 --> 01:12:36.920 of the Plan of Reorganization, is that correct? 1253 01:12:38.390 --> 01:12:40.010 I have to ask a question. 1254 01:12:40.010 --> 01:12:42.680 I don't understand what you mean by, the measures. 1255 01:12:44.100 --> 01:12:47.400 Well, in Chapter Six, 1256 01:12:55.730 --> 01:12:57.787 there's Enhanced Vegetation 1257 01:13:06.430 --> 01:13:10.530 Management Program, system hardening, 1258 01:13:11.670 --> 01:13:16.670 Wildfire Safety Inspection Program, Power Shutoff Program, 1259 01:13:19.830 --> 01:13:22.690 all of these things with the numbers. 1260 01:13:26.480 --> 01:13:31.480 Those elements, those measures, are not actually 1261 01:13:32.250 --> 01:13:34.600 in the Plan of Reorganization, is that correct? 1262 01:13:40.790 --> 01:13:43.190 I understand that certain of those costs may be, 1263 01:13:46.080 --> 01:13:47.330 but the Plan of Reorganization 1264 01:13:47.330 --> 01:13:49.480 doesn't describe any of those. 1265 01:13:49.480 --> 01:13:52.070 The Plan of Reorganization doesn't describe 1266 01:13:52.070 --> 01:13:56.430 the very detailed plans that we have 1267 01:13:56.430 --> 01:14:00.577 in our wildfire mitigation mitigation plan. 1268 01:14:02.197 --> 01:14:05.160 Now, I know this is not your testimony, 1269 01:14:05.160 --> 01:14:09.170 could you turn to page 10-3 of PG&E Volume One. 1270 01:14:20.910 --> 01:14:25.910 And on page 10-3, if you go to line nine, it states: 1271 01:14:30.340 --> 01:14:32.950 "For example, changes in rates that result 1272 01:14:32.950 --> 01:14:36.300 "from costs that PG&E would have had to incur 1273 01:14:36.300 --> 01:14:39.720 "to improve the safety of the system regardless 1274 01:14:39.720 --> 01:14:42.710 "of whether or or not PG&G emerged from Chapter 11, 1275 01:14:42.710 --> 01:14:46.610 "pursuant to PG&E's plan are independent of the plan." 1276 01:14:50.060 --> 01:14:53.790 So what does that mean, if you understand that? 1277 01:14:55.240 --> 01:14:58.790 'Cause it sounds like the costs of these measures are not, 1278 01:14:58.790 --> 01:15:01.970 that they're independent of the plan or separate. 1279 01:15:26.000 --> 01:15:28.100 And I know that is Mr. Kenney's testimony. 1280 01:15:28.960 --> 01:15:33.050 I'm sorry, I'm not an expert in this area. 1281 01:15:33.050 --> 01:15:34.167 Okay, thank you. 1282 01:15:38.690 --> 01:15:42.180 I guess, so if I understood the answer, 1283 01:15:42.180 --> 01:15:44.860 to the extent you could answer the question, 1284 01:15:44.860 --> 01:15:47.510 the specific safety measures that are identified 1285 01:15:47.510 --> 01:15:50.790 in Chapter Six are not actually incorporated 1286 01:15:50.790 --> 01:15:52.310 into the plan specifically? 1287 01:15:57.850 --> 01:16:00.430 If I pick up the Plan of Reorganization and I read it, 1288 01:16:00.430 --> 01:16:05.340 am I gonna find anything about PSPS or system hardening? 1289 01:16:09.100 --> 01:16:11.220 The Wildfire Mitigation Plan 1290 01:16:11.220 --> 01:16:12.920 or the Plan of Reorganization? 1291 01:16:12.920 --> 01:16:14.170 Plan of Reorganization. 1292 01:16:17.490 --> 01:16:19.140 I haven't been at that level of detail 1293 01:16:19.140 --> 01:16:20.960 to know an answer to that question. 1294 01:16:21.860 --> 01:16:22.693 Okay, thank you. 1295 01:16:22.693 --> 01:16:23.600 Go ahead, Mr. Abrams. 1296 01:16:25.040 --> 01:16:26.190 Your Honor thank you. 1297 01:16:30.980 --> 01:16:35.880 Given that the bankruptcy and Plan of Reorganization 1298 01:16:37.090 --> 01:16:41.220 is in direct response to the fact 1299 01:16:41.220 --> 01:16:45.140 that we've had catastrophic wildfires for 1300 01:16:45.140 --> 01:16:50.140 which your organization is charged with creating a plan 1301 01:16:50.280 --> 01:16:55.280 to address, do you find it disconcerting that your efforts 1302 01:16:56.010 --> 01:16:58.600 are disconnected from the Plan of Reorganization? 1303 01:17:04.770 --> 01:17:09.340 I don't believe our efforts are disconnected 1304 01:17:09.340 --> 01:17:11.900 from the Plan of Reorganization. 1305 01:17:13.230 --> 01:17:17.630 What I can't speak to are the details of the treatment. 1306 01:17:21.540 --> 01:17:26.240 Sorry, Ms. Powell, so I'm trying to understand this here. 1307 01:17:27.805 --> 01:17:32.030 I'm trying, if you, who is in charge of the planning 1308 01:17:32.030 --> 01:17:36.530 for wildfire mitigation, don't know to what extent 1309 01:17:36.530 --> 01:17:38.970 it's incorporated in the Plan of Reorganization, 1310 01:17:41.020 --> 01:17:44.870 then it's hard for me to understand who would. 1311 01:17:46.131 --> 01:17:47.930 I mean, this is why, I mean, if there's some other person 1312 01:17:47.930 --> 01:17:50.230 that we haven't heard from yet today 1313 01:17:50.230 --> 01:17:54.390 about how wildfire mitigation is gonna be treated 1314 01:17:54.390 --> 01:17:57.510 differently going forward, then please let us know. 1315 01:17:57.510 --> 01:18:00.260 I would ask that we add them to the proceeding. 1316 01:18:00.260 --> 01:18:05.250 But I mean that's why, primarily why we're here. 1317 01:18:05.250 --> 01:18:07.150 So can you please address that? 1318 01:18:08.660 --> 01:18:10.370 Is there somebody else who can talk 1319 01:18:10.370 --> 01:18:14.050 to how wildfire mitigation is addressed 1320 01:18:14.050 --> 01:18:15.540 in the Plan of Reorganization? 1321 01:18:15.540 --> 01:18:16.990 Is there somebody we're missing? 1322 01:18:16.990 --> 01:18:18.274 Your Honor, can we go off the record 1323 01:18:18.274 --> 01:18:21.400 for a moment? 1324 01:18:21.400 --> 01:18:22.410 Well, let's see 1325 01:18:22.410 --> 01:18:26.580 if she can answer the question first, if she knows. 1326 01:18:27.670 --> 01:18:28.880 I can't. 1327 01:18:28.880 --> 01:18:30.800 Okay, do you still want 1328 01:18:30.800 --> 01:18:32.870 to have an off-the-record discussion, Mr. Manheim? 1329 01:18:32.870 --> 01:18:33.703 Yes. 1330 01:18:33.703 --> 01:18:34.590 Let's go off the record. 1331 01:18:34.590 --> 01:18:35.740 What is it Mr. Manheim? 1332 01:18:37.180 --> 01:18:40.210 So I would be happy to clarify statement 1333 01:18:40.210 --> 01:18:42.620 of counsel, what is in our plan of reorganization 1334 01:18:42.620 --> 01:18:43.470 and what is not. 1335 01:18:43.470 --> 01:18:47.360 Ms. Powell's testified she is not working 1336 01:18:47.360 --> 01:18:48.920 on the bankruptcy matter. 1337 01:18:48.920 --> 01:18:51.590 She hasn't reviewed our Plan of Reorganization. 1338 01:18:51.590 --> 01:18:54.957 So a series of questions that ask her about that, 1339 01:18:54.957 --> 01:18:56.460 we're not gonna get anywhere, 1340 01:18:56.460 --> 01:18:59.350 because her focus is on the operation. 1341 01:18:59.350 --> 01:19:00.210 It's not on--- 1342 01:19:00.210 --> 01:19:01.900 So then let's go ahead and do that, 1343 01:19:01.900 --> 01:19:04.600 'cause she's basically answered my questions 1344 01:19:04.600 --> 01:19:07.960 and Mr. Abrams questions with, I don't know. 1345 01:19:07.960 --> 01:19:10.020 So go back on the record. 1346 01:19:10.020 --> 01:19:12.164 Mr. Manheim can make a statement of counsel. 1347 01:19:12.164 --> 01:19:14.630 Mr. Abrams before we go on the record do you 1348 01:19:14.630 --> 01:19:16.650 have something you wanted to add? 1349 01:19:16.650 --> 01:19:18.900 I do Your Honor, I guess procedurally, 1350 01:19:20.460 --> 01:19:23.580 if they're submitting testimony on Plan of Reorganization, 1351 01:19:25.300 --> 01:19:30.300 has nothing to do with Reorganization, then why's it there? 1352 01:19:31.810 --> 01:19:33.290 Why are they here? 1353 01:19:33.290 --> 01:19:34.990 Why are we considering this matter? 1354 01:19:34.990 --> 01:19:38.040 I mean, it's just they put it in the Plan of Reorganization, 1355 01:19:38.040 --> 01:19:39.520 the testimony around it. 1356 01:19:39.520 --> 01:19:41.940 It's the basis for this, I-- 1357 01:19:41.940 --> 01:19:45.190 I think there is language in 1054 1358 01:19:45.190 --> 01:19:49.560 that has language that refers to wildfire safety, 1359 01:19:49.560 --> 01:19:51.720 mostly around safety history. 1360 01:19:51.720 --> 01:19:56.280 So my guess is that they put it into show that 1361 01:19:56.280 --> 01:19:59.310 that plan takes into consideration the safety history 1362 01:20:00.720 --> 01:20:05.720 of PG&E, because AB 1054 says the Commission has 1363 01:20:05.820 --> 01:20:08.090 to consider the safety history. 1364 01:20:08.090 --> 01:20:11.770 So that's what the law says. 1365 01:20:11.770 --> 01:20:14.200 It's a slightly odd thing, 1366 01:20:14.200 --> 01:20:17.010 because it means we're looking back, rather than your point, 1367 01:20:17.010 --> 01:20:19.440 which is how we were looking forward. 1368 01:20:20.843 --> 01:20:25.280 But since 1054 required, my guess as to why it's in here 1369 01:20:25.280 --> 01:20:28.220 is my take having looked at the Plan of Reorganization 1370 01:20:28.220 --> 01:20:30.990 is these measures are not in there. 1371 01:20:32.540 --> 01:20:35.550 The Plan of Reorganization doesn't address these things 1372 01:20:35.550 --> 01:20:38.820 and according to Mr. Kenney's testimony the costs 1373 01:20:38.820 --> 01:20:41.770 of these things are not actually really addressed 1374 01:20:41.770 --> 01:20:43.530 in the Plan of Reorganization. 1375 01:20:43.530 --> 01:20:48.340 So it is a slightly odd bit of testimony, 1376 01:20:48.340 --> 01:20:51.150 'cause it's like: What am I supposed to do with it? 1377 01:20:52.360 --> 01:20:57.300 That's my take, but I'm happy to hear from Mr. Manheim 1378 01:20:57.300 --> 01:20:58.280 before we go on the record. 1379 01:20:58.280 --> 01:20:59.720 Ms. Kelly? 1380 01:20:59.720 --> 01:21:03.950 Yes, yes Your Honor. 1381 01:21:03.950 --> 01:21:07.560 If the statement of counsel would also refer 1382 01:21:07.560 --> 01:21:12.560 to how this dovetails with Section 1.75 Fire Claims 1383 01:21:13.920 --> 01:21:15.360 of the Plan, because it does refer 1384 01:21:15.360 --> 01:21:17.850 to hazard litigation costs. 1385 01:21:17.850 --> 01:21:19.180 Well let's get too-- 1386 01:21:19.180 --> 01:21:20.013 Well-- 1387 01:21:20.013 --> 01:21:21.770 Let's not go too far in detail. 1388 01:21:21.770 --> 01:21:24.490 Let's at least get the statement of-- 1389 01:21:24.490 --> 01:21:25.340 Thank you. 1390 01:21:26.280 --> 01:21:27.670 What Mr. Manheim was offering 1391 01:21:27.670 --> 01:21:29.720 and then if we need to go in more detail. 1392 01:21:29.720 --> 01:21:33.810 I also think that Mr. Kenney might be able to answer some 1393 01:21:33.810 --> 01:21:34.910 of these, 'cause he has the rates 1394 01:21:34.910 --> 01:21:38.990 and rate neutrality (mumbles) costs associated 1395 01:21:38.990 --> 01:21:41.390 with the wildfire Safety Measures. 1396 01:21:41.390 --> 01:21:44.880 Mr. Kenney would be the witness who could talk about that. 1397 01:21:47.500 --> 01:21:49.450 Does anyone I'm like totally off here? 1398 01:21:50.862 --> 01:21:53.250 (speaking off microphone) 1399 01:21:53.250 --> 01:21:54.581 Okay. 1400 01:21:54.581 --> 01:21:55.730 (speaking off microphone) 1401 01:21:55.730 --> 01:21:56.563 Okay. 1402 01:21:58.430 --> 01:22:01.930 (speaking off microphone) 1403 01:22:05.550 --> 01:22:06.860 You're right, 'cause this panel 1404 01:22:06.860 --> 01:22:09.540 doesn't actually know what's in the plan. 1405 01:22:09.540 --> 01:22:12.270 So 'cause it's not in the plan. 1406 01:22:12.270 --> 01:22:14.120 Their safety stuff's not in the plan. 1407 01:22:15.110 --> 01:22:18.900 So okay, let's go on the record. 1408 01:22:18.900 --> 01:22:20.460 Mr. Manheim, I believe you offered 1409 01:22:20.460 --> 01:22:22.600 to do a clarifying statement of counsel. 1410 01:22:22.600 --> 01:22:24.240 Yes, your Honor, thank you. 1411 01:22:24.240 --> 01:22:28.004 I think there's been some confusion about what 1412 01:22:28.004 --> 01:22:31.570 is in PG&E's Plan of Reorganization versus the testimony 1413 01:22:31.570 --> 01:22:35.700 that PG&E submitted in this proceeding and for what purpose. 1414 01:22:35.700 --> 01:22:39.920 PG&E's Plan of Reorganization is a defined document. 1415 01:22:39.920 --> 01:22:42.590 It is a plan that is before the bankruptcy court 1416 01:22:42.590 --> 01:22:44.540 and it addresses resolution of claims 1417 01:22:44.540 --> 01:22:46.230 in the bankruptcy court. 1418 01:22:46.230 --> 01:22:49.310 The plan itself does not incorporate 1419 01:22:50.760 --> 01:22:52.290 the Wildfire Mitigation Plan. 1420 01:22:52.290 --> 01:22:55.040 It does not include any costs 1421 01:22:55.040 --> 01:22:58.180 associated with PG&E's operations. 1422 01:22:58.180 --> 01:23:01.370 It solely addresses the resolution of claims 1423 01:23:01.370 --> 01:23:03.860 and the financing and the raising of capital 1424 01:23:03.860 --> 01:23:05.750 to pay those claims. 1425 01:23:05.750 --> 01:23:07.690 In this proceeding, the Commission 1426 01:23:07.690 --> 01:23:11.240 is addressing the standards in AB-1054 1427 01:23:11.240 --> 01:23:13.190 which requires the Commission to make a number 1428 01:23:13.190 --> 01:23:16.715 of findings with respect to that Plan of Reorganization. 1429 01:23:16.715 --> 01:23:21.715 And as in Ms. Powell's testimony on page 6-1, 1430 01:23:22.710 --> 01:23:26.680 as Mr. Alcantar, I believe, asked, it identifies a provision 1431 01:23:26.680 --> 01:23:30.460 of AB-1054 on page 6-1, line 20, 1432 01:23:30.460 --> 01:23:34.650 which is Public Utilities Code Section 3292(b)(1)(c), 1433 01:23:35.640 --> 01:23:38.900 which requires the Commission in evaluating 1434 01:23:38.900 --> 01:23:43.330 the Reorganization Plan and associated documents 1435 01:23:43.330 --> 01:23:47.810 to consider whether the resulting governance structure 1436 01:23:47.810 --> 01:23:51.650 is acceptable in light of the utility's safety history, 1437 01:23:51.650 --> 01:23:55.530 criminal probation, recent financial condition, 1438 01:23:55.530 --> 01:23:58.580 and other factors deemed relevant by the Commission. 1439 01:23:58.580 --> 01:24:01.610 It's in this respect that PG&E is offering testimony 1440 01:24:01.610 --> 01:24:05.930 about its Wildfire Mitigation Plan and it's ethics 1441 01:24:05.930 --> 01:24:08.840 and compliance program and it's risk program. 1442 01:24:09.710 --> 01:24:12.190 We've heard testimony from several witnesses, 1443 01:24:12.190 --> 01:24:17.190 these are all aspects of PG&E's proposal to the Commission 1444 01:24:17.380 --> 01:24:22.380 in how it will be improving its safety focus 1445 01:24:22.460 --> 01:24:24.370 and improving its culture. 1446 01:24:24.370 --> 01:24:26.650 And that is provided so that the Commission 1447 01:24:26.650 --> 01:24:30.110 can evaluate the Plan of Reorganization 1448 01:24:30.110 --> 01:24:32.600 with respect to these other programs. 1449 01:24:32.600 --> 01:24:34.890 We are not seeking cost recovery 1450 01:24:34.890 --> 01:24:37.850 of the Wildfire Mitigation Program as part 1451 01:24:37.850 --> 01:24:40.070 of the Commission's decision in this proceeding. 1452 01:24:40.070 --> 01:24:41.600 There are no costs associated 1453 01:24:41.600 --> 01:24:44.690 with wildfire mitigation in this proceeding. 1454 01:24:44.690 --> 01:24:47.750 The only costs addressed by the Plan of Reorganization 1455 01:24:47.750 --> 01:24:51.890 are the costs associated with wildfire claims 1456 01:24:51.890 --> 01:24:53.860 which are resolved through that proceeding. 1457 01:24:54.990 --> 01:24:56.520 Thank you, Mr. Manheim. 1458 01:24:56.520 --> 01:24:58.460 Mr. Abrams, is that clarifying? 1459 01:25:01.440 --> 01:25:02.540 Not really, Your Honor. 1460 01:25:02.540 --> 01:25:04.920 So here's my clarifying question 1461 01:25:04.920 --> 01:25:08.650 and whomever wants to answer it can. 1462 01:25:08.650 --> 01:25:11.720 But my clarifying request is this: 1463 01:25:11.720 --> 01:25:15.570 Unlike that characterization of the Plan of Reorganization, 1464 01:25:15.570 --> 01:25:19.092 part of what a Plan of Reorganization must show 1465 01:25:19.092 --> 01:25:22.090 is sound business judgment. 1466 01:25:22.090 --> 01:25:25.860 And it's a forward-looking description 1467 01:25:25.860 --> 01:25:28.400 of what that business judgment is 1468 01:25:28.400 --> 01:25:30.270 and that is a foundational principal 1469 01:25:30.270 --> 01:25:32.120 of the Plan of Reorganization. 1470 01:25:32.120 --> 01:25:35.890 Similarly, that aligns to what the Commission is looking at, 1471 01:25:35.890 --> 01:25:37.810 which is the safety culture, 1472 01:25:37.810 --> 01:25:41.090 which is being able to have a plan that demonstrates 1473 01:25:41.090 --> 01:25:43.860 that functionally, looking forward, 1474 01:25:43.860 --> 01:25:45.700 that we're actually gonna have a safety culture 1475 01:25:45.700 --> 01:25:48.030 within PG&E that's responsive, 1476 01:25:48.030 --> 01:25:50.750 that's different from what led them into bankruptcy. 1477 01:25:50.750 --> 01:25:52.880 So all of this is very relevant 1478 01:25:52.880 --> 01:25:55.130 and I don't see it described in this section. 1479 01:25:57.420 --> 01:25:59.890 Well, I have to say the Commission's 1480 01:25:59.890 --> 01:26:01.520 Safety Culture proceeding 1481 01:26:01.520 --> 01:26:03.870 did get somewhat interrupted by the bankruptcy. 1482 01:26:06.913 --> 01:26:10.130 Well, given that, I'm not sure you're gonna get much 1483 01:26:11.650 --> 01:26:13.730 of what you're looking for from this panel. 1484 01:26:13.730 --> 01:26:17.590 If you have some specific questions, feel free to ask them, 1485 01:26:17.590 --> 01:26:21.450 but otherwise we may need to move along. 1486 01:26:21.450 --> 01:26:26.170 And I think certainly in any briefing you do on this topic, 1487 01:26:26.170 --> 01:26:28.590 you're certainly welcome to use the statement 1488 01:26:28.590 --> 01:26:32.110 of Mr. Manheim and the answers you got from these witnesses 1489 01:26:33.540 --> 01:26:36.780 to make whatever arguments you want regarding the adequacy 1490 01:26:37.671 --> 01:26:41.450 of either the testimony and/or the Plan of Reorganization. 1491 01:26:41.450 --> 01:26:42.950 But I'm not sure you're gonna actually get 1492 01:26:42.950 --> 01:26:44.620 much more on cross-examination. 1493 01:26:45.640 --> 01:26:48.410 I will, I will try. 1494 01:26:48.410 --> 01:26:50.300 So if I can have a little more time, please. 1495 01:26:50.300 --> 01:26:52.380 Try briefly. (chuckling) 1496 01:26:52.380 --> 01:26:56.520 Okay, um, I think I did, for this panel, have anyway, 1497 01:26:56.520 --> 01:26:59.590 but, I will try to move this as quickly as possible. 1498 01:26:59.590 --> 01:27:04.590 So, Ms. Powell, continuing along with your analogy 1499 01:27:04.610 --> 01:27:09.610 of the car, I appreciate that and what I wanna understand 1500 01:27:11.470 --> 01:27:14.360 is what are those things within your plan 1501 01:27:14.360 --> 01:27:17.210 that are like my car that are gonna be based 1502 01:27:17.210 --> 01:27:20.640 on telemetry-type devices and provide some of 1503 01:27:20.640 --> 01:27:25.280 that smart grid development over the future and looking 1504 01:27:25.280 --> 01:27:28.342 into the future and what is going to entail 1505 01:27:28.342 --> 01:27:32.030 with that type of intelligence looking forward? 1506 01:27:35.320 --> 01:27:36.420 I can take that one. 1507 01:27:37.390 --> 01:27:40.260 Our Wildfire Mitigation Plan has a lot more detail 1508 01:27:40.260 --> 01:27:43.480 on emerging technologies or alternative technologies 1509 01:27:43.480 --> 01:27:45.420 that we're leveraging in our system 1510 01:27:45.420 --> 01:27:47.740 to help inform the wildfire risk 1511 01:27:47.740 --> 01:27:50.290 and further reduce that wildfire risk. 1512 01:27:50.290 --> 01:27:54.170 And so, while there's only a little bit mentioned here, 1513 01:27:54.170 --> 01:27:56.160 of course, Mr. Abrams, you're aware 1514 01:27:56.160 --> 01:27:58.300 of our extensive Wildfire Mitigation Plan 1515 01:27:58.300 --> 01:28:00.990 that was filed last month, in February, 1516 01:28:00.990 --> 01:28:03.080 where we talk about technologies 1517 01:28:03.080 --> 01:28:05.430 ranging from commercially available 1518 01:28:05.430 --> 01:28:09.070 that we are installing on our system, piloting our system, 1519 01:28:09.070 --> 01:28:14.070 to the R&D phase, right, or in the research phase 1520 01:28:15.120 --> 01:28:19.410 of just learning about how certain tools could be leveraged 1521 01:28:19.410 --> 01:28:22.100 to understand our system even better 1522 01:28:22.100 --> 01:28:23.710 and further reduce the risk. 1523 01:28:23.710 --> 01:28:27.940 So as you talk about telemetry and those kind 1524 01:28:27.940 --> 01:28:31.770 of intelligence tools, we have a section on that. 1525 01:28:31.770 --> 01:28:34.790 There are also areas of predictive modeling 1526 01:28:34.790 --> 01:28:38.370 that we are using the data streams that we currently have 1527 01:28:38.370 --> 01:28:41.350 to give us an earlier alarm bell that something 1528 01:28:41.350 --> 01:28:44.480 on our system may not be working correctly 1529 01:28:44.480 --> 01:28:47.630 and gives us extra insight to go repair that piece 1530 01:28:47.630 --> 01:28:50.640 of equipment or identify if a replacement is necessary. 1531 01:28:50.640 --> 01:28:52.260 So we can talk in more detail, 1532 01:28:52.260 --> 01:28:54.220 if you're interested in particular ones, 1533 01:28:54.220 --> 01:28:58.030 but we've outlined the asset replacement activities 1534 01:28:58.030 --> 01:29:00.290 like grid hardening, the inspection program, 1535 01:29:00.290 --> 01:29:02.960 which provides visual, either through photos 1536 01:29:02.960 --> 01:29:07.400 or the naked eye, and then we're also exploring 1537 01:29:07.400 --> 01:29:10.120 those advanced technologies or alternative technologies 1538 01:29:10.120 --> 01:29:12.720 to make the grid and our understanding of it better. 1539 01:29:13.560 --> 01:29:14.393 Thank you. 1540 01:29:19.600 --> 01:29:21.740 So I'm just looking through my questions here 1541 01:29:21.740 --> 01:29:23.740 to make sure I understand which still apply, 1542 01:29:23.740 --> 01:29:26.690 given the back and forth that we just had. 1543 01:29:33.350 --> 01:29:37.063 So Ms. Kasnitz earlier asked regarding 1544 01:29:38.900 --> 01:29:43.900 how you assess the risks associated with the power shutoffs 1545 01:29:47.430 --> 01:29:50.970 and the risks that PG&E faces with that 1546 01:29:50.970 --> 01:29:55.270 and comparatively look at what the risks are 1547 01:29:55.270 --> 01:29:58.310 to shutting off the power and what a resident might do 1548 01:29:58.310 --> 01:30:03.310 to start a fire or cause an ignition. 1549 01:30:05.810 --> 01:30:10.390 Can you help us understand how you quantify that? 1550 01:30:10.390 --> 01:30:15.390 How do you quantify your risk versus the risk 1551 01:30:15.490 --> 01:30:18.170 of the public starting a fire? 1552 01:30:21.740 --> 01:30:24.990 PG&E does not have a formula by which we attempt 1553 01:30:24.990 --> 01:30:27.640 to quantify either the risk 1554 01:30:27.640 --> 01:30:30.830 of the catastrophic fire versus public safety risk. 1555 01:30:30.830 --> 01:30:33.540 We're focused on mitigating both aspects 1556 01:30:33.540 --> 01:30:35.800 of that risk to the best of our abilities. 1557 01:30:37.890 --> 01:30:40.860 So given that that's not a quantified estimate 1558 01:30:40.860 --> 01:30:44.240 where it's 20% risk for PG&E, 1559 01:30:44.240 --> 01:30:46.780 but 10% risk for the public, 1560 01:30:46.780 --> 01:30:49.510 and therefore, you make a decision based on that, 1561 01:30:50.910 --> 01:30:55.000 can you please tell us how you evaluate that, I guess, 1562 01:30:55.000 --> 01:30:59.130 in a very subjective way, to determine what those risks are? 1563 01:30:59.130 --> 01:31:00.840 How do how do you determine that? 1564 01:31:01.890 --> 01:31:04.420 I wouldn't characterize it as subjective. 1565 01:31:04.420 --> 01:31:09.230 Our evaluation of the potential risk of catastrophic fire 1566 01:31:09.230 --> 01:31:13.510 during these high-risk weather events is data-driven. 1567 01:31:13.510 --> 01:31:16.990 It is based on essentially two main factors, 1568 01:31:16.990 --> 01:31:21.610 the potential for what we call our outage-producing winds, 1569 01:31:21.610 --> 01:31:24.570 a wind to cause an outage on our system, 1570 01:31:24.570 --> 01:31:27.500 which is essentially a proxy for a potential ignition, 1571 01:31:27.500 --> 01:31:31.780 along with the potential for, should an ignition occur, 1572 01:31:31.780 --> 01:31:34.700 a fire to spread catastrophically. 1573 01:31:34.700 --> 01:31:37.490 We measure that on what we call our fire potential index. 1574 01:31:37.490 --> 01:31:41.280 Both of these are described in our Wildfire Mitigation Plan. 1575 01:31:41.280 --> 01:31:44.790 Our meteorology and fire science team is monitoring 1576 01:31:44.790 --> 01:31:48.640 the conditions of weather forecasts constantly, even now, 1577 01:31:48.640 --> 01:31:50.760 especially during wildfire season, 1578 01:31:50.760 --> 01:31:54.520 for the potential concurrence of those two factors 1579 01:31:54.520 --> 01:31:57.850 and when they do occur on the forecast and currently, 1580 01:31:57.850 --> 01:32:01.260 is when we start to evaluate initiation of a PSPS event. 1581 01:32:02.370 --> 01:32:04.240 Given the potential scope of that event, 1582 01:32:04.240 --> 01:32:06.700 as I mentioned before, we started doing our outreach 1583 01:32:06.700 --> 01:32:09.920 to the city and county officials and public safety partners 1584 01:32:09.920 --> 01:32:12.380 to make them both aware of the potential event 1585 01:32:12.380 --> 01:32:14.790 and to gather information on what impacts 1586 01:32:14.790 --> 01:32:16.680 may occur as a result of de-energization. 1587 01:32:16.680 --> 01:32:18.250 Thank you. 1588 01:32:18.250 --> 01:32:21.250 It's really the assessment that I'm trying to focus on here. 1589 01:32:22.180 --> 01:32:25.200 And so the criteria that you just described 1590 01:32:26.610 --> 01:32:31.590 are the same criteria for PG&E as it is for the public. 1591 01:32:31.590 --> 01:32:34.840 So if you just described the wind and weather and all 1592 01:32:34.840 --> 01:32:38.680 of those things are gonna exist where my home is located 1593 01:32:40.130 --> 01:32:42.470 and where the power line is above my home. 1594 01:32:43.870 --> 01:32:48.250 So my question is, is how are you assessing 1595 01:32:48.250 --> 01:32:53.250 the relative risk of PG&E versus the public? 1596 01:32:54.310 --> 01:32:57.540 So what are those measures that you look at? 1597 01:32:57.540 --> 01:33:01.600 So the measure of, you know, someone running out 1598 01:33:01.600 --> 01:33:05.560 and generators and looking at the statistics associated 1599 01:33:05.560 --> 01:33:08.910 with what is the likelihood of a generator-caused fire 1600 01:33:08.910 --> 01:33:11.840 or a campfire that somebody's trying 1601 01:33:11.840 --> 01:33:13.670 to cook their food before the food goes bad 1602 01:33:13.670 --> 01:33:16.630 in their refrigerator, all sorts of risks 1603 01:33:16.630 --> 01:33:20.850 associated with the public during power shutoffs. 1604 01:33:22.300 --> 01:33:24.780 So how, you know, none of what you described there 1605 01:33:24.780 --> 01:33:25.613 gets to that. 1606 01:33:25.613 --> 01:33:29.320 How do you take those factors into consideration, 1607 01:33:29.320 --> 01:33:31.890 based on the events that you have before you, 1608 01:33:31.890 --> 01:33:33.140 for a particular shutoff? 1609 01:33:38.660 --> 01:33:42.450 PG&E is not attempting to ensure 1610 01:33:42.450 --> 01:33:46.840 that the public broadly does not create fire risk. 1611 01:33:46.840 --> 01:33:50.910 I think that is an onus of ours to ensure 1612 01:33:50.910 --> 01:33:53.940 that our equipment does not ignite fires. 1613 01:33:53.940 --> 01:33:58.340 We do work to educate our customers on potential fire risks 1614 01:33:58.340 --> 01:34:00.090 associated with de-energization, 1615 01:34:00.090 --> 01:34:03.110 largely around generator use. 1616 01:34:03.110 --> 01:34:07.050 But, we do rely on our local officials, CAL FIRE 1617 01:34:07.050 --> 01:34:09.660 and other firefighting agencies to broadly ensure 1618 01:34:09.660 --> 01:34:13.040 that the public is aware, even outside of de-energization, 1619 01:34:13.040 --> 01:34:16.180 of the potential of fires in California 1620 01:34:16.180 --> 01:34:18.250 being sparked from a variety of sources. 1621 01:34:22.700 --> 01:34:26.500 So given that, those risks are not calculated 1622 01:34:26.500 --> 01:34:29.160 or known to PG&E are not factored in. 1623 01:34:30.120 --> 01:34:33.740 Are you not concerned, as a customer 1624 01:34:33.740 --> 01:34:37.040 or someone who's living in PG&E territory, 1625 01:34:37.040 --> 01:34:39.540 that given that you're only assessing one side 1626 01:34:39.540 --> 01:34:43.130 of the equation, which are the risks to PG&E 1627 01:34:44.230 --> 01:34:48.130 or the risks that PG&E could cause and not the other side 1628 01:34:48.130 --> 01:34:53.130 of the equation that there could be a extreme weather event 1629 01:34:53.450 --> 01:34:56.990 where it actually would be better, 1630 01:34:56.990 --> 01:34:59.460 might be still risky for PG&E, to some extent, 1631 01:34:59.460 --> 01:35:01.960 but the risks are higher for the public 1632 01:35:01.960 --> 01:35:04.190 in terms of what their actions are 1633 01:35:04.190 --> 01:35:06.390 and that you're not looking at that at all? 1634 01:35:06.390 --> 01:35:08.010 Is that not a concern of yours? 1635 01:35:10.070 --> 01:35:11.650 I don't think it's a fair characterization 1636 01:35:11.650 --> 01:35:13.540 to say that we're not looking at it at all. 1637 01:35:13.540 --> 01:35:16.830 I think that our outreach campaigns and education 1638 01:35:16.830 --> 01:35:19.430 around fire season awareness and partnership 1639 01:35:19.430 --> 01:35:22.780 with local fire councils point to us recognizing 1640 01:35:22.780 --> 01:35:24.880 that fire risk needs to be recognized 1641 01:35:24.880 --> 01:35:26.340 broadly across California. 1642 01:35:27.490 --> 01:35:30.970 But our focus during PSPS events is to ensure 1643 01:35:30.970 --> 01:35:34.150 that our assets do not ignite a catastrophic fire. 1644 01:35:37.750 --> 01:35:41.870 Mr. Pender, you mentioned in your testimony a little bit 1645 01:35:41.870 --> 01:35:45.630 earlier that you have a quality assurance program 1646 01:35:46.784 --> 01:35:48.984 and that you have a quality control program. 1647 01:35:49.860 --> 01:35:52.300 That's a little different than my understanding. 1648 01:35:52.300 --> 01:35:54.400 So can you help me understand what makes 1649 01:35:54.400 --> 01:35:56.180 a quality assurance program 1650 01:35:56.180 --> 01:35:57.740 and a quality control program 1651 01:35:57.740 --> 01:35:59.380 and how those are different? 1652 01:35:59.380 --> 01:36:02.900 So as it relates to our vegetation management programs, 1653 01:36:02.900 --> 01:36:04.890 we have quality assurance programs 1654 01:36:05.790 --> 01:36:08.050 for both our routine vegetation management 1655 01:36:08.050 --> 01:36:11.910 and our enhanced vegetation management. 1656 01:36:11.910 --> 01:36:16.190 Those quality assurance programs take a sample 1657 01:36:16.190 --> 01:36:19.060 of the work that we've performed or of the areas 1658 01:36:19.060 --> 01:36:23.750 in our system and assess those locations 1659 01:36:25.740 --> 01:36:28.900 from just comparing the vegetation 1660 01:36:28.900 --> 01:36:31.510 in those areas as compared to our standards 1661 01:36:31.510 --> 01:36:33.850 or the regulatory requirements. 1662 01:36:33.850 --> 01:36:38.330 And so, regardless of how recently those areas were worked 1663 01:36:38.330 --> 01:36:42.370 or who performed the work, that quality assurance assessment 1664 01:36:42.370 --> 01:36:44.540 is trying to assess the entire process, 1665 01:36:44.540 --> 01:36:49.050 our whole process of activity, to see if the outcomes 1666 01:36:49.050 --> 01:36:52.820 in our system match what we desire, right. 1667 01:36:52.820 --> 01:36:55.440 And so was the process successful 1668 01:36:55.440 --> 01:36:56.570 in giving us what we wanted, 1669 01:36:56.570 --> 01:36:58.420 in the terms of routine veg management. 1670 01:36:58.420 --> 01:37:00.580 Are the trees far enough away from our lines 1671 01:37:00.580 --> 01:37:03.900 to not violate the minimum compliance requirements? 1672 01:37:03.900 --> 01:37:07.840 Quality control is much closer to the performance 1673 01:37:07.840 --> 01:37:11.040 of the work, and is assessing did each person 1674 01:37:11.040 --> 01:37:14.150 in the process do what their job was. 1675 01:37:14.150 --> 01:37:17.190 So did the pre-inspector identify the right trees 1676 01:37:17.190 --> 01:37:18.360 to then be trimmed? 1677 01:37:18.360 --> 01:37:22.080 Did the tree trimming company trim the trees 1678 01:37:22.080 --> 01:37:24.740 or remove the trees to our standard 1679 01:37:24.740 --> 01:37:26.700 and in the way that they were instructed? 1680 01:37:26.700 --> 01:37:31.130 And so the quality control, also called work verification 1681 01:37:31.130 --> 01:37:33.480 for our enhanced vegetation management program, 1682 01:37:33.480 --> 01:37:37.960 is the caboose behind our work process, 1683 01:37:37.960 --> 01:37:41.150 behind our tree trimmers doing the work, our QC, 1684 01:37:41.150 --> 01:37:43.510 or work verification inspectors, 1685 01:37:43.510 --> 01:37:46.640 are following right behind them to check the work 1686 01:37:46.640 --> 01:37:48.510 and make sure that things were performed 1687 01:37:48.510 --> 01:37:50.860 and each person did their job correctly. 1688 01:37:50.860 --> 01:37:55.740 So together those two activities, the kind of similar 1689 01:37:55.740 --> 01:37:59.820 and related, provide us a more robust perspective 1690 01:37:59.820 --> 01:38:01.930 on the performance of our process. 1691 01:38:01.930 --> 01:38:05.550 QC provides us an insight into are people 1692 01:38:05.550 --> 01:38:08.510 in the process doing the right things and QA tries 1693 01:38:08.510 --> 01:38:10.300 to provide a higher level perspective 1694 01:38:10.300 --> 01:38:13.180 is the overall process getting us the outcomes we want. 1695 01:38:14.160 --> 01:38:16.410 Okay, so the traditional description 1696 01:38:16.410 --> 01:38:19.550 of a quality control as a measuring tool 1697 01:38:19.550 --> 01:38:21.290 and the measure is not something 1698 01:38:21.290 --> 01:38:25.180 that PG&E considers a quality control? 1699 01:38:25.180 --> 01:38:26.530 You look at it differently? 1700 01:38:27.620 --> 01:38:29.380 I don't understand the question, sorry. 1701 01:38:29.380 --> 01:38:34.380 So quality control, in a total quality management plan, 1702 01:38:35.460 --> 01:38:39.420 is typically the tool that you're measuring with, 1703 01:38:39.420 --> 01:38:41.640 the monitoring tool, if you will, 1704 01:38:41.640 --> 01:38:46.110 along with the measure that you are looking at, 1705 01:38:46.110 --> 01:38:51.110 wind speed or system hardening or whatever that measure 1706 01:38:51.700 --> 01:38:54.650 is and so that's the quality control 1707 01:38:54.650 --> 01:38:57.630 that's part of your quality assurance program. 1708 01:38:59.310 --> 01:39:01.720 So are you saying that the quality controls 1709 01:39:01.720 --> 01:39:03.700 that you're talking about are not part 1710 01:39:03.700 --> 01:39:06.690 of your quality assurance program, 1711 01:39:06.690 --> 01:39:08.720 like a total quality management plan? 1712 01:39:12.370 --> 01:39:16.320 We would consider our overall quality program 1713 01:39:16.320 --> 01:39:19.310 to include our quality control efforts 1714 01:39:19.310 --> 01:39:23.090 and our quality assurance process programs, 1715 01:39:24.080 --> 01:39:26.960 as our comprehensive view of quality, 1716 01:39:26.960 --> 01:39:29.580 particularly in the space of enhanced vegetation management. 1717 01:39:29.580 --> 01:39:33.520 So QC, as I outlined previously, 1718 01:39:33.520 --> 01:39:36.450 QC being more narrowly focused on each piece 1719 01:39:36.450 --> 01:39:38.600 of the puzzle doing its job 1720 01:39:38.600 --> 01:39:41.040 and QA looking over all of the process. 1721 01:39:43.130 --> 01:39:46.440 How do you ensure PSPS notifications are effective? 1722 01:39:52.620 --> 01:39:55.000 Our goal is to ensure that customers are notified 1723 01:39:55.000 --> 01:39:57.930 in advance of events and we strive 1724 01:39:57.930 --> 01:40:00.270 to provide as clear communication 1725 01:40:00.270 --> 01:40:02.500 about the potential timing and impacts 1726 01:40:02.500 --> 01:40:04.400 of the events in those communications. 1727 01:40:05.250 --> 01:40:08.460 We did learn coming out of the large-scale events 1728 01:40:08.460 --> 01:40:12.340 that we conducted last year, we received a lot of feedback 1729 01:40:12.340 --> 01:40:16.390 on how to improve those and our customer organization 1730 01:40:16.390 --> 01:40:18.270 has been reaching out to customers 1731 01:40:18.270 --> 01:40:20.169 in a variety of different ways to get 1732 01:40:20.169 --> 01:40:21.002 (coughing drowns out speaker) 1733 01:40:21.002 --> 01:40:22.900 on what kinds of information they want 1734 01:40:22.900 --> 01:40:24.420 to see in those notifications. 1735 01:40:25.780 --> 01:40:29.380 Some of those venues include customer focus groups 1736 01:40:29.380 --> 01:40:31.720 across the service territory to get direct feedback 1737 01:40:31.720 --> 01:40:35.900 about their experience and working through sort of, 1738 01:40:35.900 --> 01:40:37.770 you know, sessions with customers, again, 1739 01:40:37.770 --> 01:40:41.290 so that we can work to improve the process of notifications 1740 01:40:41.290 --> 01:40:43.880 and the information that we're providing accordingly. 1741 01:40:50.440 --> 01:40:53.500 Earlier you indicated that you're not sure 1742 01:40:53.500 --> 01:40:56.910 what the next wildfire season will hold. 1743 01:40:59.420 --> 01:41:02.590 As PG&E's looking ahead to this wildfire season 1744 01:41:03.690 --> 01:41:07.150 and given the fact that, at least from what I've looked at, 1745 01:41:07.150 --> 01:41:11.563 the precipitation levels for February are record lows, 1746 01:41:15.000 --> 01:41:18.320 what is your expectation about the risks 1747 01:41:18.320 --> 01:41:20.190 going into this wildfire season? 1748 01:41:22.820 --> 01:41:25.490 I'm not a meteorologist, so I can't prognosticate 1749 01:41:25.490 --> 01:41:28.070 on what fire season's going to look like. 1750 01:41:29.510 --> 01:41:30.800 I agree with you, I'm concerned 1751 01:41:30.800 --> 01:41:33.500 that we haven't had as much precipitation as we would like. 1752 01:41:33.500 --> 01:41:36.360 I was encouraged by seeing a little bit over the weekend. 1753 01:41:36.360 --> 01:41:40.570 Dryness is one factor, the amount of fuels available 1754 01:41:40.570 --> 01:41:45.140 to potentially contribute to a catastrophic fire 1755 01:41:45.140 --> 01:41:48.150 is another aspect and then just the number 1756 01:41:48.150 --> 01:41:49.620 of wind events that come through, 1757 01:41:49.620 --> 01:41:53.420 which we have no visibility into the potential of. 1758 01:41:53.420 --> 01:41:55.660 So it's hard to come up with even a guess. 1759 01:41:57.004 --> 01:41:58.460 I don't know that you could pin any meteorologist 1760 01:41:58.460 --> 01:42:00.630 down right now with an estimate 1761 01:42:00.630 --> 01:42:02.380 of what the season would look like. 1762 01:42:08.080 --> 01:42:10.110 So with your first iteration 1763 01:42:10.110 --> 01:42:11.770 of the Wildfire Mitigation Plan, 1764 01:42:11.770 --> 01:42:15.010 you filed a second amendment to that plan 1765 01:42:15.010 --> 01:42:17.490 and in that second amendment, among other things, 1766 01:42:17.490 --> 01:42:21.740 you changed targets, you crossed out results 1767 01:42:21.740 --> 01:42:26.740 as the basis for how you would assess vegetation management. 1768 01:42:27.218 --> 01:42:31.110 And the Commission did not move forward with that amendment, 1769 01:42:32.050 --> 01:42:33.800 but through that process, 1770 01:42:33.800 --> 01:42:37.150 it seemed that right before wildfire season 1771 01:42:38.580 --> 01:42:40.820 there was a changing of the goalposts. 1772 01:42:42.210 --> 01:42:45.910 How do we ensure through the Plan of Reorganization 1773 01:42:45.910 --> 01:42:49.170 and through a course correction for PG&E 1774 01:42:49.170 --> 01:42:53.460 that what you talk about in your testimony 1775 01:42:54.530 --> 01:42:59.530 and the specifics within the Wildfire Mitigation Plan 1776 01:42:59.560 --> 01:43:04.560 are things that we can count on versus things that we will 1777 01:43:04.570 --> 01:43:07.600 have a change right before we go into wildfire season, 1778 01:43:07.600 --> 01:43:11.220 depending upon how risky you 1779 01:43:11.220 --> 01:43:13.680 then assessed the season's going to be? 1780 01:43:15.640 --> 01:43:20.370 So that's a important topic, 1781 01:43:20.370 --> 01:43:23.500 which is continuous improvement and therefore, 1782 01:43:23.500 --> 01:43:26.990 some evolution and change in our tactics 1783 01:43:26.990 --> 01:43:28.440 and activities as it relates 1784 01:43:28.440 --> 01:43:30.710 to the Wildfire Mitigation Plan. 1785 01:43:32.120 --> 01:43:34.810 So as you mentioned, last year, 1786 01:43:34.810 --> 01:43:37.350 between when we filed our initial plan on February 6th 1787 01:43:37.350 --> 01:43:40.300 and when we filed our second amendment on April 25th, 1788 01:43:40.300 --> 01:43:43.350 I believe, we already began to learn some things 1789 01:43:43.350 --> 01:43:46.860 about how different activities were playing out in the field 1790 01:43:46.860 --> 01:43:48.440 and what would be effective 1791 01:43:48.440 --> 01:43:51.750 or less effective in mitigating wildfire risk. 1792 01:43:51.750 --> 01:43:54.620 And so our second amendment last year 1793 01:43:54.620 --> 01:43:57.320 reflected our latest and greatest insight 1794 01:43:57.320 --> 01:44:00.800 into how we would perform our activities. 1795 01:44:00.800 --> 01:44:04.250 As, if you compare our 2019 Wildfire Safety Plan 1796 01:44:04.250 --> 01:44:07.520 to our 2020 Wildfire Mitigation Plan, you see evolution 1797 01:44:07.520 --> 01:44:11.500 in a number of our programs and continuous learning, 1798 01:44:11.500 --> 01:44:15.780 PSPS being a big factor there, or a big area 1799 01:44:15.780 --> 01:44:18.570 where we've added additional programs and activities. 1800 01:44:18.570 --> 01:44:23.570 And so, we all are on this continuous improvement 1801 01:44:27.390 --> 01:44:29.470 and continuous learning journey together 1802 01:44:29.470 --> 01:44:34.470 and so that's what you should take from that process, right, 1803 01:44:34.840 --> 01:44:36.630 the fact that we filed a second amendment, 1804 01:44:36.630 --> 01:44:39.240 the fact that we continue to move forward 1805 01:44:39.240 --> 01:44:43.960 and learn from what we did in 2019 to inform our 2020 plan. 1806 01:44:43.960 --> 01:44:47.050 So-- Sorry, my question, 1807 01:44:47.050 --> 01:44:52.050 if I can, is really around the trust gap. 1808 01:44:53.270 --> 01:44:58.270 So we've had horrific wildfire seasons. 1809 01:44:59.360 --> 01:45:03.110 We've had plans provided by PG&E 1810 01:45:03.110 --> 01:45:06.720 that were changed right before wildfire season. 1811 01:45:08.190 --> 01:45:11.120 For the public to be able to look for the Commission 1812 01:45:11.120 --> 01:45:13.910 to be able to look at your Wildfire Mitigation Plan 1813 01:45:13.910 --> 01:45:18.260 and count on it for how PG&E's going to respond 1814 01:45:18.260 --> 01:45:22.300 in wildfire season, as opposed to changing the goalposts, 1815 01:45:22.300 --> 01:45:26.180 how can we trust, how can we have confidence that a plan 1816 01:45:26.180 --> 01:45:30.860 of reorganization is not gonna produce changing goalposts, 1817 01:45:30.860 --> 01:45:34.720 is not gonna produce, you know, 1818 01:45:34.720 --> 01:45:36.320 how is there gonna be accountability, 1819 01:45:36.320 --> 01:45:37.830 if you can change the goalposts. 1820 01:45:37.830 --> 01:45:40.970 How is the Commission gonna understand that and the public? 1821 01:45:40.970 --> 01:45:45.970 So accountability and continuous improvement 1822 01:45:50.130 --> 01:45:54.170 can go together as part of an ongoing partnership 1823 01:45:55.650 --> 01:45:59.620 and evolution between PG&E and our regulators 1824 01:45:59.620 --> 01:46:03.640 and our public and partners, stakeholders like yourself. 1825 01:46:03.640 --> 01:46:08.320 And so we were very transparent through the 2019 process, 1826 01:46:08.320 --> 01:46:10.090 Wildfire Safety Plan process, 1827 01:46:10.090 --> 01:46:12.630 about what we were learning and where we were at. 1828 01:46:12.630 --> 01:46:14.470 The second amendment was not adopted. 1829 01:46:14.470 --> 01:46:15.890 We didn't change the goalposts. 1830 01:46:15.890 --> 01:46:18.470 We continued to report our performance 1831 01:46:18.470 --> 01:46:21.340 against the original goalposts, if you will, 1832 01:46:21.340 --> 01:46:24.340 the original targets expressed in our Wildfire Safety Plan 1833 01:46:24.340 --> 01:46:26.960 and there are expected to be, you know, 1834 01:46:26.960 --> 01:46:29.490 independent evaluator process and such 1835 01:46:29.490 --> 01:46:33.240 to evaluate how the utilities did, 1836 01:46:33.240 --> 01:46:35.630 including PG&E, against our plan. 1837 01:46:35.630 --> 01:46:40.630 So we appreciate the trust gap that you mentioned 1838 01:46:40.800 --> 01:46:45.220 and the challenge with helping all 1839 01:46:45.220 --> 01:46:48.500 of those stakeholders understand what we're working 1840 01:46:48.500 --> 01:46:51.030 towards and why those are the right things to work towards. 1841 01:46:51.030 --> 01:46:53.350 That's what the 2020 Wildfire Mitigation Plan 1842 01:46:53.350 --> 01:46:55.169 proceeding is all about, 1843 01:46:55.169 --> 01:46:56.900 making sure that we're pursuing the right activities. 1844 01:46:56.900 --> 01:47:01.190 So what I would say is that our objectives 1845 01:47:01.190 --> 01:47:04.440 and the focus that we have on reducing wildfire risk 1846 01:47:04.440 --> 01:47:07.550 and reducing the risk of PSPS remains unwavering 1847 01:47:07.550 --> 01:47:10.210 and that will be what you see 1848 01:47:10.210 --> 01:47:14.380 and see consistent action towards. 1849 01:47:14.380 --> 01:47:15.780 But, I do think you'll see 1850 01:47:15.780 --> 01:47:17.630 continuous evolution and improvement. 1851 01:47:17.630 --> 01:47:20.900 It would be imprudent for us not to continue 1852 01:47:20.900 --> 01:47:25.340 to learn lessons and adjust, as necessary and we'll continue 1853 01:47:25.340 --> 01:47:26.750 to do that in a transparent way 1854 01:47:26.750 --> 01:47:28.360 through these public proceedings, 1855 01:47:28.360 --> 01:47:30.590 that it includes stakeholder input. 1856 01:47:30.590 --> 01:47:32.293 Okay, thank you. 1857 01:47:32.293 --> 01:47:34.793 I've got two more questions and then I'll be done. 1858 01:47:40.040 --> 01:47:43.720 Are you aware of the implications of your work 1859 01:47:44.920 --> 01:47:49.070 on the insurance rates of homeowners? 1860 01:47:53.180 --> 01:47:57.340 A bit, but we're far from experts on this. 1861 01:47:57.340 --> 01:48:00.500 I've participated in some panels 1862 01:48:00.500 --> 01:48:02.970 and conferences at the state level, 1863 01:48:02.970 --> 01:48:05.700 in particular, with representatives 1864 01:48:05.700 --> 01:48:07.610 from the State Insurance Commission 1865 01:48:08.900 --> 01:48:10.810 and there's been much discussion about this, 1866 01:48:10.810 --> 01:48:15.570 but it's not something that we're experts on 1867 01:48:15.570 --> 01:48:18.610 or have any input on, in particular. 1868 01:48:20.921 --> 01:48:25.240 Okay, so in terms of the implications though, 1869 01:48:25.240 --> 01:48:27.040 I just wanna try to understand 1870 01:48:27.040 --> 01:48:28.720 if you understand the implications. 1871 01:48:28.720 --> 01:48:33.170 So there are wildfire survivors, victims, 1872 01:48:33.170 --> 01:48:38.170 who are rebuilding their homes from the PG&E wildfires 1873 01:48:39.140 --> 01:48:41.880 and they wanna understand is that investment, 1874 01:48:42.890 --> 01:48:46.360 that significant family investment, 1875 01:48:46.360 --> 01:48:49.170 going to be a one-year investment 1876 01:48:49.170 --> 01:48:52.760 or a two-year investment or a long-term investment 1877 01:48:52.760 --> 01:48:55.550 and they see insurance scarcity growing. 1878 01:48:56.460 --> 01:49:01.460 And do you understand the implications to PG&E's work 1879 01:49:03.960 --> 01:49:08.010 to mitigate wildfires is directly tied 1880 01:49:08.010 --> 01:49:09.500 to those insurance rates? 1881 01:49:11.160 --> 01:49:14.380 So while I can't speak to the direct tie 1882 01:49:14.380 --> 01:49:16.960 between PG&E's activities and insurance rates, 1883 01:49:16.960 --> 01:49:21.330 I just don't know that market or regulation set well, 1884 01:49:21.330 --> 01:49:26.330 we completely understand that concern from our customers 1885 01:49:27.800 --> 01:49:30.210 and residents of our service territory 1886 01:49:30.210 --> 01:49:33.510 and we are very focused, as I just mentioned, 1887 01:49:33.510 --> 01:49:36.890 on reducing the risk of wildfire to all of the communities 1888 01:49:36.890 --> 01:49:41.870 that we serve and focusing on the PSPS impact 1889 01:49:41.870 --> 01:49:46.160 that also impacts our customers' livelihoods 1890 01:49:46.160 --> 01:49:50.080 or quality of life during that period of time. 1891 01:49:50.080 --> 01:49:53.240 So can't speak to the insurance aspect of it, 1892 01:49:53.240 --> 01:49:56.590 but can speak obviously extensively to our activities 1893 01:49:56.590 --> 01:49:58.680 and our focus on reducing the wildfire risk 1894 01:49:58.680 --> 01:50:00.130 to protect those communities. 1895 01:50:01.100 --> 01:50:05.220 So given that the Commission is charged with ensuring 1896 01:50:05.220 --> 01:50:09.170 that the plan of reorganization is oriented 1897 01:50:09.170 --> 01:50:14.170 towards a safety culture and oriented towards customers 1898 01:50:14.830 --> 01:50:18.740 not having increased financial burdens, 1899 01:50:20.560 --> 01:50:23.210 do you not think that it would be a prudent step 1900 01:50:23.210 --> 01:50:28.210 to ensure that very specifically and very quantitatively 1901 01:50:29.140 --> 01:50:33.230 that your work, through the Plan of Reorganization, 1902 01:50:33.230 --> 01:50:36.300 is tied to partners in the insurance industry 1903 01:50:36.300 --> 01:50:40.295 to make sure that we have more 1904 01:50:40.295 --> 01:50:45.073 of a comprehensive approach where we have corporate partners 1905 01:50:46.160 --> 01:50:49.520 working together on the path ahead? 1906 01:50:53.990 --> 01:50:56.440 I certainly understand the point you're making, 1907 01:50:57.750 --> 01:51:02.360 but there is a whole other regulatory scheme as it relates 1908 01:51:02.360 --> 01:51:04.910 to insurance in the State of California right? 1909 01:51:04.910 --> 01:51:09.490 There's a whole 'nother regulatory body that leads that. 1910 01:51:09.490 --> 01:51:13.470 And so, while we are more than open to being a part 1911 01:51:13.470 --> 01:51:17.460 of that conversation or contributing to those proceedings, 1912 01:51:17.460 --> 01:51:21.930 if you will, that's just not an area that we're experts in, 1913 01:51:21.930 --> 01:51:25.350 or implicitly have any control over. 1914 01:51:25.350 --> 01:51:29.410 Happy to participate, again, but yeah, 1915 01:51:29.410 --> 01:51:31.750 not our core competency. 1916 01:51:31.750 --> 01:51:34.480 Okay, so sorry, one last question, 1917 01:51:34.480 --> 01:51:38.000 because of what you stated there. 1918 01:51:38.000 --> 01:51:40.120 So the Commission has been looking 1919 01:51:40.120 --> 01:51:42.950 at something called a customer arm threshold 1920 01:51:42.950 --> 01:51:47.950 to understand what can be reasonably charged to customers. 1921 01:51:48.290 --> 01:51:53.290 And so insurance rates and cost of living increases 1922 01:51:54.190 --> 01:51:58.260 and those types of things are customer arms. 1923 01:51:58.260 --> 01:52:03.120 So would you not see that as sort of central to your role 1924 01:52:03.120 --> 01:52:05.130 in terms of a Plan of Reorganization 1925 01:52:05.130 --> 01:52:08.120 and how you understand cost to customers? 1926 01:52:11.610 --> 01:52:16.610 Unfortunately, I don't see that large-scale question 1927 01:52:18.240 --> 01:52:21.040 about the cost to residents or customers 1928 01:52:21.040 --> 01:52:25.060 as being something solvable by PG&E 1929 01:52:25.060 --> 01:52:27.110 in this proceeding or related proceedings. 1930 01:52:27.110 --> 01:52:29.730 I mean that's a large, again, that's things outside 1931 01:52:29.730 --> 01:52:33.270 of PG&E's control that we can contribute to or, you know, 1932 01:52:33.270 --> 01:52:34.550 maybe be a part of the conversation. 1933 01:52:34.550 --> 01:52:39.370 But, basically, I don't agree that that's something 1934 01:52:39.370 --> 01:52:43.190 that is within the scope of PG&E's Plan of Reorganization; 1935 01:52:45.230 --> 01:52:46.910 insurance rates, in particular. 1936 01:52:48.220 --> 01:52:49.950 Even on a collaborative basis? 1937 01:52:49.950 --> 01:52:52.460 I thought you just said that part of this is collaboration. 1938 01:52:52.460 --> 01:52:55.040 And I thought, you know, nothing is on the whole. 1939 01:52:55.040 --> 01:52:56.950 You're having a whole bunch of collaborative partners-- 1940 01:52:56.950 --> 01:52:58.800 Mr. Abrams, I think he's answered it 1941 01:52:58.800 --> 01:52:59.760 to the best of his ability. 1942 01:52:59.760 --> 01:53:01.630 I think the answer's pretty clear. 1943 01:53:01.630 --> 01:53:04.940 Okay, I see PG&E counsel upset by my questions, 1944 01:53:04.940 --> 01:53:06.534 so I'll stop there, thank you. 1945 01:53:06.534 --> 01:53:07.580 (chuckling) 1946 01:53:07.580 --> 01:53:10.350 I would note that I did not see any more 1947 01:53:10.350 --> 01:53:12.504 than the normal upset from PG&E counsel. 1948 01:53:12.504 --> 01:53:14.754 (laughing) 1949 01:53:15.900 --> 01:53:16.880 Thank you, Mr. Abrams. 1950 01:53:16.880 --> 01:53:18.430 I have a few questions. 1951 01:53:18.430 --> 01:53:21.620 I think what I'll do is, I have a few questions. 1952 01:53:21.620 --> 01:53:22.790 I dunno, Commissioner Rechtschaffen 1953 01:53:22.790 --> 01:53:24.200 may have a question or two. 1954 01:53:24.200 --> 01:53:26.210 After that, we'll take an afternoon break. 1955 01:53:28.430 --> 01:53:32.690 Just so I'm clear, how does the testimony here 1956 01:53:32.690 --> 01:53:35.980 on wildfire safety relate 1957 01:53:35.980 --> 01:53:39.010 to PG&E's 2020 Wildfire Mitigation Plan? 1958 01:53:39.010 --> 01:53:41.220 What's the relationship or connection? 1959 01:53:41.220 --> 01:53:44.430 So this is a very summarized version, right? 1960 01:53:44.430 --> 01:53:47.180 I think I have six pages of testimony here compared 1961 01:53:47.180 --> 01:53:50.660 to there's 485 pages of testimony, 1962 01:53:50.660 --> 01:53:53.800 or in our original plan as part 1963 01:53:53.800 --> 01:53:55.780 of the Wildfire Mitigation Plan proceeding. 1964 01:53:55.780 --> 01:54:00.200 So this is an appetizer to what's going on 1965 01:54:00.200 --> 01:54:02.290 in the Wildfire Mitigation Plan proceeding, 1966 01:54:02.290 --> 01:54:05.820 the purpose of which is to dig into the actions we're taking 1967 01:54:05.820 --> 01:54:08.260 and to assess and determine, 1968 01:54:08.260 --> 01:54:11.730 are those the right actions at the right scope and scale, 1969 01:54:11.730 --> 01:54:14.380 and how should they be, if anything, 1970 01:54:14.380 --> 01:54:17.820 adjusted from what we've proposed in our plan. 1971 01:54:17.820 --> 01:54:21.760 So this is essentially just a summary of that plan? 1972 01:54:21.760 --> 01:54:22.960 Right, which is ongoing. 1973 01:54:22.960 --> 01:54:23.793 Okay. 1974 01:54:27.140 --> 01:54:30.430 One of the issues that's been raised in this proceeding 1975 01:54:30.430 --> 01:54:32.990 is the concept of regionalization 1976 01:54:32.990 --> 01:54:35.150 and changing essentially some 1977 01:54:35.150 --> 01:54:38.310 of the management structures of PG&E. 1978 01:54:38.310 --> 01:54:41.620 Are you familiar with the regionalization concept? 1979 01:54:41.620 --> 01:54:43.390 At a very high level. 1980 01:54:45.710 --> 01:54:50.430 How does, how do the regionalization proposals 1981 01:54:50.430 --> 01:54:52.380 that are put forward in this proceeding 1982 01:54:53.630 --> 01:54:56.040 impact the Wildfire Mitigation Plan, 1983 01:54:56.040 --> 01:54:57.730 either 2020 or going forward? 1984 01:55:00.330 --> 01:55:04.530 I don't see that they impact the Wildfire Mitigation Plan. 1985 01:55:04.530 --> 01:55:06.440 Regionalization, the concept there 1986 01:55:06.440 --> 01:55:09.820 is to have PG&E leadership and employees 1987 01:55:09.820 --> 01:55:13.920 in local areas having really strong relationships 1988 01:55:13.920 --> 01:55:15.390 with the local communities, 1989 01:55:15.390 --> 01:55:18.290 and people know who each other are 1990 01:55:18.290 --> 01:55:23.290 and to the extent that that helps inform, you know, 1991 01:55:23.558 --> 01:55:28.190 PSPS or the Wildfire Mitigation Plan, I see that as helpful, 1992 01:55:29.150 --> 01:55:30.890 but, what we've put in the plan 1993 01:55:30.890 --> 01:55:34.460 is a commitment by the company that we will continue 1994 01:55:34.460 --> 01:55:38.170 to execute, no matter the final structure. 1995 01:55:39.110 --> 01:55:44.110 So are there, there'll be regional safety positions, 1996 01:55:44.340 --> 01:55:45.173 is that correct? 1997 01:55:46.980 --> 01:55:47.813 Or do you know? 1998 01:55:50.010 --> 01:55:51.680 I guess the question is-- I couldn't testify 1999 01:55:51.680 --> 01:55:53.460 to that, but I've heard it. 2000 01:55:53.460 --> 01:55:55.470 Okay, if there are something 2001 01:55:55.470 --> 01:56:00.470 like a regional safety position, how would that relate 2002 01:56:01.260 --> 01:56:04.600 to the bigger wildfire safety measures 2003 01:56:04.600 --> 01:56:07.233 and the Wildfire Mitigation Plan, if you know? 2004 01:56:12.190 --> 01:56:13.031 I don't. 2005 01:56:13.031 --> 01:56:14.423 Well-- 2006 01:56:14.423 --> 01:56:16.360 Go ahead. 2007 01:56:16.360 --> 01:56:20.130 Maybe one way to expand on your question: 2008 01:56:20.130 --> 01:56:23.170 Would it help with improving wildfire safety 2009 01:56:23.170 --> 01:56:25.470 or would it be neutral or hinder it, 2010 01:56:27.090 --> 01:56:28.290 at a regional structure? 2011 01:56:31.540 --> 01:56:33.830 The safety or the safety officer 2012 01:56:33.830 --> 01:56:35.140 or the regional structure? 2013 01:56:35.140 --> 01:56:36.880 I'm gonna make sure I understood the question. 2014 01:56:36.880 --> 01:56:40.520 The regional structure that PG&E proposed 2015 01:56:40.520 --> 01:56:43.350 and that was in the Assigned Commissioner Ruling 2016 01:56:43.350 --> 01:56:47.530 and just the the idea of some regional decentralization. 2017 01:56:47.530 --> 01:56:49.800 Judge Allen was asking about how it would relate 2018 01:56:49.800 --> 01:56:51.300 to the Wildfire Safety Plan. 2019 01:56:51.300 --> 01:56:54.610 So I'm asking you if you could, if you wanna expand 2020 01:56:54.610 --> 01:56:57.220 on what you said a little bit ago 2021 01:56:57.220 --> 01:57:00.350 about its relationship to improving safety. 2022 01:57:00.350 --> 01:57:02.560 Is there anything else you would wanna say 2023 01:57:02.560 --> 01:57:05.200 about how it could improve or promote safety? 2024 01:57:07.200 --> 01:57:09.400 Well I'm in Operations. 2025 01:57:09.400 --> 01:57:13.540 I always like to see more safety resources deployed 2026 01:57:13.540 --> 01:57:16.730 and in a regional area where they know, you know, 2027 01:57:17.914 --> 01:57:19.230 the people in the area very closely. 2028 01:57:19.230 --> 01:57:24.230 I can see that adding, especially during the PSPS events, 2029 01:57:24.260 --> 01:57:27.150 in having additional safety resource 2030 01:57:27.150 --> 01:57:29.780 in our local operating centers. 2031 01:57:29.780 --> 01:57:33.750 Also have a safety advocate. 2032 01:57:33.750 --> 01:57:35.840 A very strong safety advocate 2033 01:57:35.840 --> 01:57:38.663 no matter what issues come up within the company. 2034 01:57:44.328 --> 01:57:49.328 I had a, (clearing throat) excuse me, I had a few 2035 01:57:49.770 --> 01:57:54.720 questions for you, Ms. Maratukulam, about the PSPSs 2036 01:57:55.840 --> 01:58:00.030 and you said you scheduled listening sessions 2037 01:58:00.030 --> 01:58:02.060 with each of the impacted areas. 2038 01:58:03.850 --> 01:58:06.530 I don't know if you happened to listen 2039 01:58:06.530 --> 01:58:10.960 to the Commission's voting meeting last Thursday 2040 01:58:10.960 --> 01:58:12.310 or had anyone report to you 2041 01:58:12.310 --> 01:58:14.950 about what was said at the voting meeting? 2042 01:58:15.900 --> 01:58:18.380 I was not able to listen to it, no. 2043 01:58:18.380 --> 01:58:21.420 Well, the short of it was Commissioner Guzman Aceves 2044 01:58:21.420 --> 01:58:25.410 went at the invitation of Supervisor Moke Simon, 2045 01:58:25.410 --> 01:58:27.320 who is from Lake County. 2046 01:58:27.320 --> 01:58:31.850 And Lake County has a special working group on PSPSs, 2047 01:58:32.900 --> 01:58:35.120 course they've been devastated by wildfires 2048 01:58:35.120 --> 01:58:37.370 over the past several years. 2049 01:58:37.370 --> 01:58:41.847 And they experienced wildfires, either one long one 2050 01:58:43.100 --> 01:58:47.880 or several ones that lasted most of a week in 2019. 2051 01:58:49.300 --> 01:58:51.360 And what Commissioner Guzman Aceves reported 2052 01:58:51.360 --> 01:58:55.100 is that PG&E had made a number of commitments 2053 01:58:55.100 --> 01:58:56.750 to the community going forward, 2054 01:58:57.820 --> 01:59:01.400 including something about working with the local government. 2055 01:59:01.400 --> 01:59:04.140 But what became apparent at that meeting was 2056 01:59:04.140 --> 01:59:07.030 that PG&E hasn't followed up on some of those? 2057 01:59:07.030 --> 01:59:10.080 And so for example PG&E doesn't currently 2058 01:59:10.080 --> 01:59:13.140 have a local liaison assigned to Lake County. 2059 01:59:13.140 --> 01:59:15.780 Lake County has to share with other counties. 2060 01:59:15.780 --> 01:59:19.470 PG&E was unaware that one of its local government contacts 2061 01:59:19.470 --> 01:59:21.870 had been retired for over two months. 2062 01:59:21.870 --> 01:59:24.900 And there were other discussions at this working group 2063 01:59:24.900 --> 01:59:28.610 about the plans going forward 2064 01:59:28.610 --> 01:59:30.790 for 2020 that hadn't materialized. 2065 01:59:34.078 --> 01:59:35.730 Are you aware of any of this? 2066 01:59:35.730 --> 01:59:38.480 I'm not aware of the specifics from Lake County, no. 2067 01:59:38.480 --> 01:59:43.480 All right, well, this concerned us as Commissioners 2068 01:59:43.730 --> 01:59:46.710 and I'm wondering if you can either here 2069 01:59:46.710 --> 01:59:48.910 or in another context follow up with us 2070 01:59:48.910 --> 01:59:53.550 about what your plans are for Lake County in specific? 2071 01:59:53.550 --> 01:59:57.030 Happy to, yes. 2072 01:59:57.030 --> 01:59:59.490 How many community resource centers 2073 01:59:59.490 --> 02:00:01.150 are you planning for 2020? 2074 02:00:01.150 --> 02:00:04.870 I saw in your testimony you say that PG&E 2075 02:00:04.870 --> 02:00:08.190 has mobilized 80 Community Resource Centers. 2076 02:00:08.190 --> 02:00:10.680 Are you planning for more than that? 2077 02:00:10.680 --> 02:00:13.260 We are, we had deployed, I believe, 2078 02:00:13.260 --> 02:00:15.340 it was approximately 80, over 70 2079 02:00:15.340 --> 02:00:18.310 in one event in the 2019 season. 2080 02:00:19.410 --> 02:00:21.710 I cannot recall the number off the top of my head 2081 02:00:21.710 --> 02:00:23.090 of how many we're targeting 2082 02:00:23.090 --> 02:00:26.402 to have pre-established agreements with. 2083 02:00:26.402 --> 02:00:28.130 I did note earlier that we're trying 2084 02:00:28.130 --> 02:00:30.620 to work with property owners now 2085 02:00:30.620 --> 02:00:33.680 to establish hardened facilities 2086 02:00:33.680 --> 02:00:37.850 rather than rely on space to set up tents. 2087 02:00:37.850 --> 02:00:39.992 But I cannot recall the number off the top of my head. 2088 02:00:39.992 --> 02:00:40.825 Matt may have it. 2089 02:00:40.825 --> 02:00:42.550 In our Wildfire Mitigation Plan, we identified four 2090 02:00:42.550 --> 02:00:45.290 to five hardened facilities as in, you know, 2091 02:00:45.290 --> 02:00:48.480 permanent structures per county that's likely to be impacted 2092 02:00:48.480 --> 02:00:50.070 or that's within PSPS footprint, 2093 02:00:50.070 --> 02:00:51.320 which is around 40 counties. 2094 02:00:51.320 --> 02:00:55.140 So we're looking at 150 to 200 sites 2095 02:00:55.140 --> 02:00:56.850 pre-established to be ready. 2096 02:00:56.850 --> 02:00:58.790 And then during any given event, 2097 02:00:58.790 --> 02:01:00.790 the appropriate ones would be activated. 2098 02:01:01.870 --> 02:01:03.060 Are those in the process 2099 02:01:03.060 --> 02:01:06.820 of both being identified and secured by contract 2100 02:01:06.820 --> 02:01:11.470 and otherwise made ready for the event? 2101 02:01:11.470 --> 02:01:15.980 Yes, as well in consultation with the county leadership 2102 02:01:15.980 --> 02:01:18.100 and some cases city leadership to make sure 2103 02:01:18.100 --> 02:01:19.100 those are the right locations 2104 02:01:19.100 --> 02:01:21.780 and that those fit with their plans as well. 2105 02:01:21.780 --> 02:01:23.890 When do you anticipate that all the arrangements 2106 02:01:23.890 --> 02:01:27.850 for these 150 to 200 will be finalized? 2107 02:01:27.850 --> 02:01:28.683 I don't know. 2108 02:01:28.683 --> 02:01:29.920 I know that we've already made good progress. 2109 02:01:29.920 --> 02:01:33.255 But we could follow up with what timeline we have. 2110 02:01:33.255 --> 02:01:37.490 I mean, September 1 is our peak start of PSPS season. 2111 02:01:37.490 --> 02:01:38.820 So in advance of September 1 2112 02:01:38.820 --> 02:01:41.270 is when we want all of this stuff to be in place. 2113 02:01:43.000 --> 02:01:44.320 Okay, the fire season may start 2114 02:01:44.320 --> 02:01:46.240 before September 1 as we all know. 2115 02:01:47.730 --> 02:01:51.110 Let me ask one last question, and this is a follow-up 2116 02:01:51.110 --> 02:01:53.810 to the questions from Ms. Kasnitz at C4AT 2117 02:01:55.115 --> 02:01:57.130 and if you went over this, I apologize, 2118 02:01:57.130 --> 02:02:01.880 but for medically-vulnerable customers who are not customers 2119 02:02:01.880 --> 02:02:03.830 of PG&E, who don't have their own account, 2120 02:02:03.830 --> 02:02:05.780 who are behind a master meter 2121 02:02:05.780 --> 02:02:09.220 like a mobile home park tenant, or Section-8 tenant, 2122 02:02:10.110 --> 02:02:13.210 how are you learning of those customers 2123 02:02:13.210 --> 02:02:15.910 and how are you notifying them of PSPS events? 2124 02:02:15.910 --> 02:02:17.060 Yeah, they are still encouraged 2125 02:02:17.060 --> 02:02:19.000 to enroll with the Medical Baseline Program. 2126 02:02:19.000 --> 02:02:21.350 So while they may not be the tenant of record, 2127 02:02:21.350 --> 02:02:23.410 we are aware of Medical Baseline customers 2128 02:02:23.410 --> 02:02:25.030 that are under a master meter. 2129 02:02:25.030 --> 02:02:26.930 And we do work to notify them directly 2130 02:02:26.930 --> 02:02:29.210 as we do all other medical baseline customers. 2131 02:02:30.190 --> 02:02:32.260 Are you working with the local community-based 2132 02:02:32.260 --> 02:02:34.740 organizations and local governments 2133 02:02:34.740 --> 02:02:36.430 to identify those customers? 2134 02:02:36.430 --> 02:02:40.463 Yes, in 2019 we had outreach seeking 2135 02:02:40.463 --> 02:02:43.060 to inform the public of the program 2136 02:02:43.060 --> 02:02:45.550 and increase awareness and participation. 2137 02:02:45.550 --> 02:02:48.300 We're doing the same this year also in partnership 2138 02:02:48.300 --> 02:02:49.820 with community-based organizations 2139 02:02:49.820 --> 02:02:51.780 to help further get the word out. 2140 02:02:51.780 --> 02:02:54.560 We will be working directly through those organizations 2141 02:02:54.560 --> 02:02:58.640 as well as mass media campaigns to increase awareness 2142 02:02:58.640 --> 02:03:02.156 and participation in the Medical Baseline Program. 2143 02:03:02.156 --> 02:03:03.082 Thank you. 2144 02:03:03.082 --> 02:03:07.840 Thank you, Judge. 2145 02:03:07.840 --> 02:03:09.123 Thank you. 2146 02:03:09.123 --> 02:03:12.820 So my plan after the break is that Ms. Yap 2147 02:03:12.820 --> 02:03:15.720 will take the stand and my plan would be 2148 02:03:15.720 --> 02:03:18.790 to complete the cross-examination of Ms. Yap today 2149 02:03:20.050 --> 02:03:22.360 And also allow for Ms. Sheriff's 2150 02:03:24.770 --> 02:03:27.540 estimated brief cross-examination of Mr. Kenney, 2151 02:03:29.460 --> 02:03:31.040 plus any clean up we do. 2152 02:03:31.040 --> 02:03:34.270 So based on numbers in front of me, 2153 02:03:34.270 --> 02:03:37.350 we may go past four o'clock, 2154 02:03:37.350 --> 02:03:39.320 but that's my plan for this afternoon. 2155 02:03:39.320 --> 02:03:41.970 Anything to do before we take our or afternoon break? 2156 02:03:43.040 --> 02:03:45.820 Seeing none, let's be back by 3:15 p.m. 2157 02:03:45.820 --> 02:03:47.610 by the clock on the wall. 2158 02:03:47.610 --> 02:03:48.443 Off the record. 2159 02:03:57.150 --> 02:03:57.983 On the record. 2160 02:03:59.060 --> 02:04:00.300 Good afternoon. 2161 02:04:00.300 --> 02:04:04.150 We're in Investigation 19-09-016. 2162 02:04:04.150 --> 02:04:06.060 Ms. Sheriff, call your witness, please. 2163 02:04:07.550 --> 02:04:08.580 Thank you, your Honor. 2164 02:04:08.580 --> 02:04:10.710 Nora Sheriff for the California Large Energy 2165 02:04:10.710 --> 02:04:12.410 Consumers Association. 2166 02:04:12.410 --> 02:04:14.860 I would like to call Ms. Catherine Yap to the stand. 2167 02:04:16.670 --> 02:04:19.016 Thank you, Ms. Sheriff. 2168 02:04:19.016 --> 02:04:20.616 Do you swear to tell the truth, 2169 02:04:20.616 --> 02:04:22.444 the whole truth and nothing but the truth? 2170 02:04:22.444 --> 02:04:23.277 I do. 2171 02:04:23.277 --> 02:04:24.470 Thank you, please be seated. 2172 02:04:24.470 --> 02:04:25.380 State your full name. 2173 02:04:25.380 --> 02:04:27.070 Spell your last name for the record. 2174 02:04:31.020 --> 02:04:34.580 My name is Catherine E. Yap. 2175 02:04:34.580 --> 02:04:35.670 Spelled Y-A-P. 2176 02:04:38.840 --> 02:04:39.740 Thank you. 2177 02:04:39.740 --> 02:04:40.840 Go ahead, Ms. Sheriff. 2178 02:04:42.670 --> 02:04:44.260 Good afternoon, Ms. Yap. 2179 02:04:46.080 --> 02:04:48.070 You have before you what has been marked 2180 02:04:48.070 --> 02:04:52.350 for identification as exhibit CLECA-01? 2181 02:04:52.350 --> 02:04:53.570 Yes, I do. 2182 02:04:53.570 --> 02:04:55.680 Do you have before you what has been marked 2183 02:04:55.680 --> 02:04:59.410 for identification as Exhibit CLECA-01-E, 2184 02:04:59.410 --> 02:05:01.290 which is the reply testimony 2185 02:05:01.290 --> 02:05:03.050 of Catherine E. Yap on behalf 2186 02:05:03.050 --> 02:05:07.550 of the California Large Energy Consumers Association Errata? 2187 02:05:07.550 --> 02:05:08.815 Yes, I do. 2188 02:05:08.815 --> 02:05:11.316 Do you also have before you what has been marked, 2189 02:05:11.316 --> 02:05:15.060 or what I would ask to have marked for identification 2190 02:05:15.060 --> 02:05:18.490 as exhibit CLECA-02, which is a CLECA response 2191 02:05:18.490 --> 02:05:21.610 to a PG&E data request, CLECA-001? 2192 02:05:22.850 --> 02:05:23.860 Yes, I do. 2193 02:05:23.860 --> 02:05:24.820 Thank you. 2194 02:05:24.820 --> 02:05:29.467 CLECA response to PG&E data request PG&E CLECA-001! 2195 02:05:31.520 --> 02:05:35.000 is identified as CLECA Exhibit 2. 2196 02:05:35.880 --> 02:05:37.030 Thank you Your Honor. 2197 02:05:38.980 --> 02:05:43.000 Ms. Yap, was this information in these three exhibits 2198 02:05:43.000 --> 02:05:46.020 prepared by you or under your supervision? 2199 02:05:46.020 --> 02:05:47.460 Yes, they were. 2200 02:05:47.460 --> 02:05:50.000 To the extent that it contains facts, 2201 02:05:50.000 --> 02:05:51.700 are those facts true and correct 2202 02:05:51.700 --> 02:05:53.060 to the best of your knowledge? 2203 02:05:53.060 --> 02:05:54.400 Yes, they are. 2204 02:05:54.400 --> 02:05:58.600 To the extent that they contain professional opinions, 2205 02:05:58.600 --> 02:06:00.940 are those your best professional opinions? 2206 02:06:00.940 --> 02:06:02.160 Yes, they are. 2207 02:06:02.160 --> 02:06:03.970 And do you have any changes to make 2208 02:06:03.970 --> 02:06:06.390 to your testimony at this time? 2209 02:06:06.390 --> 02:06:08.080 No, I do not. 2210 02:06:08.080 --> 02:06:09.320 Thank you, Ms. Yap. 2211 02:06:09.320 --> 02:06:12.070 Your Honor, Ms. Yap is available for cross-examination. 2212 02:06:13.020 --> 02:06:14.290 According to what I have there 2213 02:06:14.290 --> 02:06:18.750 is cross for Ms. Yap from PG&E, from EPUC, 2214 02:06:20.180 --> 02:06:22.660 and from TCC; is that correct? 2215 02:06:24.520 --> 02:06:28.690 Let's start with, any preference of starting? 2216 02:06:28.690 --> 02:06:31.120 I was thinking of starting PG&E. 2217 02:06:31.120 --> 02:06:33.570 Let's go with PG&E with cross. 2218 02:06:34.450 --> 02:06:36.280 Okay, Your Honor, Kevin Allred. 2219 02:06:36.280 --> 02:06:38.730 One administrative point that I've just realized. 2220 02:06:38.730 --> 02:06:42.430 The data response that was marked does not 2221 02:06:42.430 --> 02:06:46.160 have the attached, which is rather important for any cross. 2222 02:06:47.060 --> 02:06:48.300 Which exhibit is this? 2223 02:06:48.300 --> 02:06:50.360 Is this is a PG&E's exhibit or-- 2224 02:06:50.360 --> 02:06:52.290 It's the data response 2225 02:06:52.290 --> 02:06:54.780 that was just marked as the exhibit. 2226 02:06:54.780 --> 02:06:56.730 Exhibit CLECA-02. 2227 02:06:56.730 --> 02:06:59.070 There is an Excel spreadsheet that's embedded 2228 02:06:59.070 --> 02:07:04.070 in the paper copy, and I do not have the ability at home 2229 02:07:06.340 --> 02:07:08.820 to produce that Excel spreadsheet. 2230 02:07:08.820 --> 02:07:10.170 Okay, off the record. 2231 02:07:11.510 --> 02:07:16.200 Okay, so you're saying it's incomplete and that needs to be, 2232 02:07:18.275 --> 02:07:19.108 or should be added to it? 2233 02:07:19.108 --> 02:07:21.540 Or is it workable with it is-- 2234 02:07:21.540 --> 02:07:23.890 Ms. Yapp, how large is the spreadsheet 2235 02:07:24.980 --> 02:07:29.650 that's embedded in response to question one. 2236 02:07:29.650 --> 02:07:32.810 I know you have pulled out some of the tables. 2237 02:07:33.760 --> 02:07:38.313 It's probably two pages per tab maybe. 2238 02:07:42.560 --> 02:07:43.500 One or two pages-- 2239 02:07:43.500 --> 02:07:44.830 I now have it, it's not very large. 2240 02:07:44.830 --> 02:07:46.680 I could hand out, I have four copies. 2241 02:07:47.940 --> 02:07:49.480 You can provide it 2242 02:07:49.480 --> 02:07:50.850 for the record. I can arrange 2243 02:07:50.850 --> 02:07:53.150 to have more copies brought in either 2244 02:07:53.150 --> 02:07:56.430 through Mr. Alcantar or someone else tomorrow. 2245 02:07:56.430 --> 02:07:58.830 And those can just be appended to, 2246 02:08:00.867 --> 02:08:03.865 with a stapler we can just add those to, we could do right? 2247 02:08:03.865 --> 02:08:04.698 Yes Your Honor, I think so. 2248 02:08:04.698 --> 02:08:08.610 Okay, so you have four copies? 2249 02:08:08.610 --> 02:08:11.290 Okay, we may need to do a sharing 2250 02:08:11.290 --> 02:08:13.380 of those four to accommodate cross. 2251 02:08:13.380 --> 02:08:16.730 Why don't we make sure that Ms. Sheriff, 2252 02:08:16.730 --> 02:08:20.430 the witness and whoever's doing cross-examination has, 2253 02:08:20.430 --> 02:08:22.940 do you have that available to-- 2254 02:08:24.189 --> 02:08:25.520 I have it electronically. 2255 02:08:25.520 --> 02:08:27.480 I don't have a paper copy of it. 2256 02:08:27.480 --> 02:08:30.680 That's probably okay. 2257 02:08:30.680 --> 02:08:34.138 From my perspective, it's actually preferable. 2258 02:08:34.138 --> 02:08:35.110 (chuckling) 2259 02:08:35.110 --> 02:08:38.360 Okay, so we'll go ahead, 2260 02:08:38.360 --> 02:08:39.670 let's see, on the record. 2261 02:08:41.469 --> 02:08:43.350 While off the record, we had a discussion 2262 02:08:43.350 --> 02:08:48.350 about Exhibit CLECA-02, which the copy that was distributed, 2263 02:08:49.140 --> 02:08:52.758 is missing a related spreadsheet. 2264 02:08:52.758 --> 02:08:55.000 There appear to be adequate copies 2265 02:08:55.000 --> 02:09:00.000 in the hearing room for us to conduct cross-examination. 2266 02:09:00.250 --> 02:09:05.250 And then Ms. Sheriff will provide additional copies 2267 02:09:05.520 --> 02:09:10.240 of the spreadsheet, which will be attached to CLECA-02 2268 02:09:10.240 --> 02:09:12.040 before it is admitted to the record. 2269 02:09:13.630 --> 02:09:15.390 With that, Mr. Allred. 2270 02:09:16.320 --> 02:09:17.496 Yes, your Honor. 2271 02:09:17.496 --> 02:09:19.160 May I approach the witness to hand out copies 2272 02:09:19.160 --> 02:09:20.160 of what we just referenced? 2273 02:09:20.160 --> 02:09:21.130 Yes, you may. 2274 02:09:23.965 --> 02:09:28.965 I think I have, oh okay, good, okay. 2275 02:09:33.650 --> 02:09:34.710 Off the record. 2276 02:09:36.074 --> 02:09:36.907 I got, is this-- 2277 02:09:37.960 --> 02:09:40.096 There's two different tabs to the Excel. 2278 02:09:40.096 --> 02:09:40.929 Okay, so that's what this is? 2279 02:09:40.929 --> 02:09:42.150 Okay thanks. 2280 02:09:42.150 --> 02:09:46.200 I'm not gonna mark this now, but I'll just use it for today. 2281 02:09:48.065 --> 02:09:52.630 Thank you Judge. 2282 02:09:52.630 --> 02:09:53.700 Okay, are we ready? 2283 02:09:53.700 --> 02:09:54.912 Yes Your Honor. 2284 02:09:54.912 --> 02:09:58.680 On the record. 2285 02:10:05.650 --> 02:10:09.430 You handed me actually two different spreadsheets. 2286 02:10:09.430 --> 02:10:13.000 'Cause one looks like my work paper. 2287 02:10:13.000 --> 02:10:14.683 Off the record. 2288 02:10:14.683 --> 02:10:15.940 Let's make sure we're clear. 2289 02:10:18.212 --> 02:10:19.450 Which is a single page. 2290 02:10:22.250 --> 02:10:25.270 And the other which is paper clipped together 2291 02:10:25.270 --> 02:10:27.450 is the re-worked version. 2292 02:10:27.450 --> 02:10:29.560 The data points are attached to spreadsheets. 2293 02:10:29.560 --> 02:10:31.530 These are the two spreadsheets that are referenced 2294 02:10:31.530 --> 02:10:34.527 and embedded within the data response. 2295 02:10:34.527 --> 02:10:36.860 Okay, I just wanted to be clear though 2296 02:10:36.860 --> 02:10:41.860 that we were talking about two separate spreadsheets, 2297 02:10:42.090 --> 02:10:44.760 one of which has multiple pages. 2298 02:10:44.760 --> 02:10:46.600 Yeah, there's one multiple-page document 2299 02:10:46.600 --> 02:10:48.720 and one single-page document. 2300 02:10:48.720 --> 02:10:49.820 It's a single page document. 2301 02:10:49.820 --> 02:10:52.360 I believe the single-page document corresponds 2302 02:10:52.360 --> 02:10:56.080 to your question one response, which is your work paper. 2303 02:10:56.080 --> 02:10:58.210 Yes, it's my original work paper 2304 02:10:59.120 --> 02:11:04.120 and then the second one was my re-working of a PG&E response 2305 02:11:06.480 --> 02:11:10.340 to a TURN data request, just to make it really confusing. 2306 02:11:10.340 --> 02:11:13.340 Okay, when I go on the record, 2307 02:11:13.340 --> 02:11:14.340 who wants to clarify that? 2308 02:11:14.340 --> 02:11:16.240 Do you wanna do it or Mr. Allred? 2309 02:11:16.240 --> 02:11:18.200 I could do it and perhaps to help further, 2310 02:11:18.200 --> 02:11:20.090 I have taken the multi-page 2311 02:11:20.090 --> 02:11:22.170 and condensed it onto a single page. 2312 02:11:22.170 --> 02:11:23.910 I could hand that out and that might maybe-- 2313 02:11:23.910 --> 02:11:25.715 No, that's just gonna confuse everyone. 2314 02:11:25.715 --> 02:11:26.970 (laughing) 2315 02:11:26.970 --> 02:11:28.670 Besides, it'd be an eye test. 2316 02:11:29.990 --> 02:11:30.950 On the record. 2317 02:11:30.950 --> 02:11:32.410 Mr. Allred I believe there needs 2318 02:11:32.410 --> 02:11:35.260 to be a slight clarification of the document 2319 02:11:35.260 --> 02:11:36.260 that was handed out. 2320 02:11:37.330 --> 02:11:39.740 We have handed out what I understood 2321 02:11:39.740 --> 02:11:42.350 to be attachments to the data response 2322 02:11:42.350 --> 02:11:44.330 that was marked as CLECA-02. 2323 02:11:44.330 --> 02:11:47.320 The first one was the first, the one-pager 2324 02:11:47.320 --> 02:11:49.170 is the first attachment and what is printed 2325 02:11:49.170 --> 02:11:52.100 is multiple pages, what you would call your re-work 2326 02:11:53.410 --> 02:11:55.040 is the second attachment. 2327 02:11:56.204 --> 02:11:57.037 Do you have those in front of you? 2328 02:11:57.037 --> 02:12:01.130 Yes, I do and just to be nauseatingly clear, 2329 02:12:01.130 --> 02:12:04.060 the single page one was the response 2330 02:12:04.060 --> 02:12:07.300 to question one of your data request. 2331 02:12:07.300 --> 02:12:10.320 And I believe the multiple page one was 2332 02:12:10.320 --> 02:12:13.240 in response to question three. 2333 02:12:15.586 --> 02:12:17.730 For purposes of cross-examination 2334 02:12:17.730 --> 02:12:19.920 and to make sure that the record 2335 02:12:19.920 --> 02:12:22.840 is clear for the single page one, 2336 02:12:22.840 --> 02:12:24.720 let's call that document Sources, 2337 02:12:24.720 --> 02:12:29.150 because it has the word sources in all caps at the top. 2338 02:12:29.150 --> 02:12:32.790 And on the other one, let's call it Cost of Debt Detail, 2339 02:12:32.790 --> 02:12:35.530 because that's what appears in the footer on the first page. 2340 02:12:38.470 --> 02:12:41.400 And ultimately these will end up as part of CLECA-02. 2341 02:12:44.026 --> 02:12:45.585 Go ahead Mr. Allred. 2342 02:12:45.585 --> 02:12:46.418 Thank you, your Honor. 2343 02:12:46.418 --> 02:12:47.700 Let's actually set that aside for a moment. 2344 02:12:47.700 --> 02:12:48.533 We'll get back to it. 2345 02:12:48.533 --> 02:12:49.750 Good afternoon, Ms. Yap. 2346 02:12:49.750 --> 02:12:51.180 Good afternoon. 2347 02:12:51.180 --> 02:12:54.090 Take a look at what has been marked PG&E-X-01. 2348 02:12:54.090 --> 02:12:56.090 It's the thick document in front of you. 2349 02:12:58.110 --> 02:13:00.710 And I believe it is what is referenced 2350 02:13:00.710 --> 02:13:05.710 in page 19 of your testimony at lines 11 to 13. 2351 02:13:11.315 --> 02:13:13.640 I'm going to stop you right there. 2352 02:13:13.640 --> 02:13:15.870 Mine didn't get marked. 2353 02:13:15.870 --> 02:13:17.690 So is this what we're referring to? 2354 02:13:17.690 --> 02:13:19.220 It is a thick document. 2355 02:13:19.220 --> 02:13:21.680 It was left for me up here. 2356 02:13:24.630 --> 02:13:25.730 Off the record. 2357 02:13:28.220 --> 02:13:29.053 Okay. 2358 02:13:34.920 --> 02:13:36.612 On the record. 2359 02:13:36.612 --> 02:13:39.570 Actually, we have not marked these 2360 02:13:39.570 --> 02:13:42.250 on the record yet have we, Mr. Allred? 2361 02:13:42.250 --> 02:13:43.083 I don't believe so. 2362 02:13:43.083 --> 02:13:44.120 I believe your Honor has them, 2363 02:13:44.120 --> 02:13:45.730 but I don't know if it was on the record. 2364 02:13:45.730 --> 02:13:46.910 I believe not. 2365 02:13:46.910 --> 02:13:51.140 So I understand that PG&E has two exhibits they wish 2366 02:13:51.140 --> 02:13:54.880 to have marked as cross-examination exhibits. 2367 02:13:54.880 --> 02:13:56.620 Is that correct, Mr. Allred? 2368 02:13:56.620 --> 02:13:57.580 Yes, your Honor. 2369 02:13:57.580 --> 02:14:01.480 So first one I have titled 2370 02:14:01.480 --> 02:14:06.210 PG&E Hearing Room Exhibit, the caption of this case, 2371 02:14:06.210 --> 02:14:09.640 then it says, Financing Order Authorizing the Issuance 2372 02:14:09.640 --> 02:14:12.470 of Energy Recovery Bonds Pursuant 2373 02:14:12.470 --> 02:14:17.290 to Senate Bill 772 is marked as PG&E-X-01. 2374 02:14:19.310 --> 02:14:24.310 The second one, a smaller document, PG&E's Hearing Room 2375 02:14:25.020 --> 02:14:30.020 Exhibit CLECA's Response to PG&E Data Request 001, 2376 02:14:30.190 --> 02:14:35.110 Questions six, seven, and eight is marked as PG&E-X-02. 2377 02:14:38.460 --> 02:14:39.293 Go ahead. 2378 02:14:39.293 --> 02:14:40.126 Thank you, Your Honor. 2379 02:14:41.030 --> 02:14:46.030 Ms. Yap, if you'll look at your testimony at page 19, 2380 02:14:46.220 --> 02:14:48.010 lines 11 to 13. 2381 02:14:55.540 --> 02:14:58.860 You state there quote, "It is noteworthy that 2382 02:14:58.860 --> 02:15:01.620 "in its previous bankruptcy proceeding, 2383 02:15:01.620 --> 02:15:04.380 "PG&E's authorization to recover the cost 2384 02:15:04.380 --> 02:15:06.390 "of its debt financed associated 2385 02:15:06.390 --> 02:15:10.560 "with its POR was limited to 25 million dollars." 2386 02:15:10.560 --> 02:15:11.393 Closed quote. 2387 02:15:11.393 --> 02:15:12.280 Do you see that? 2388 02:15:12.280 --> 02:15:13.113 Yes. 2389 02:15:13.113 --> 02:15:15.780 And you footnote that to what I believe 2390 02:15:15.780 --> 02:15:20.000 is the document we have marked as PG&E-X-01 2391 02:15:20.000 --> 02:15:25.000 CPUC Decision 04-11-015, Financing Order 2392 02:15:25.790 --> 02:15:27.660 Authorizing Bond Issuance's. 2393 02:15:27.660 --> 02:15:29.110 Is that the correct document? 2394 02:15:34.430 --> 02:15:36.510 Yes, that's the document I cited. 2395 02:15:36.510 --> 02:15:39.090 And if looking at that exhibit, X-01, 2396 02:15:39.931 --> 02:15:41.660 if you turn to page 26 and 27, 2397 02:15:41.660 --> 02:15:43.860 which is the pages you cite in the footnote, 2398 02:15:52.330 --> 02:15:56.180 at the bottom there there's a section F Bond Issuance Cost. 2399 02:15:56.180 --> 02:15:57.013 Do you see that? 2400 02:15:58.640 --> 02:15:59.640 Yes. 2401 02:15:59.640 --> 02:16:04.590 And this section relates to the utility's 2402 02:16:04.590 --> 02:16:07.150 post emergence bond issuance, correct? 2403 02:16:08.660 --> 02:16:09.493 Yes. 2404 02:16:09.493 --> 02:16:12.010 So it's not referring to the exit financing cost 2405 02:16:12.010 --> 02:16:14.460 associated with emergence from bankruptcy, right? 2406 02:16:26.220 --> 02:16:27.053 You are correct. 2407 02:16:27.053 --> 02:16:30.890 It's the issuance cost for the energy recovery bonds. 2408 02:16:32.440 --> 02:16:35.680 Also at the bottom of page 26, in that first sentence 2409 02:16:35.680 --> 02:16:40.680 of that section it says that PG&E estimates the costs 2410 02:16:41.040 --> 02:16:45.240 in question here as 21.663 million, correct? 2411 02:16:52.050 --> 02:16:57.050 Yes, the decision on page 26 does cite 21.663 million. 2412 02:16:57.200 --> 02:17:02.200 And at page 27 in the middle paragraph 2413 02:17:03.820 --> 02:17:05.360 the decision says quote: 2414 02:17:05.360 --> 02:17:08.580 "We adopt PG&E's unopposed proposal 2415 02:17:08.580 --> 02:17:12.820 "to cap bond issuance cost at 25 million 2416 02:17:12.820 --> 02:17:15.050 "plus costs for the Commission financing team." 2417 02:17:15.050 --> 02:17:16.338 Closed quote. 2418 02:17:16.338 --> 02:17:17.171 Do you see that? 2419 02:17:17.171 --> 02:17:18.004 Yes, I do. 2420 02:17:18.004 --> 02:17:20.280 So to clarify, this was not a situation 2421 02:17:20.280 --> 02:17:23.990 where PG&E sought to recover financing costs 2422 02:17:23.990 --> 02:17:26.160 and the Commission limited the recovery 2423 02:17:26.160 --> 02:17:28.480 to some lesser amount, correct? 2424 02:17:28.480 --> 02:17:30.020 That is correct. 2425 02:17:30.020 --> 02:17:32.990 And in fact it was an unopposed request for a cap 2426 02:17:32.990 --> 02:17:35.690 that PG&E said up front it would come in under, right? 2427 02:17:36.620 --> 02:17:39.830 That's the stated language of the decision. 2428 02:17:43.420 --> 02:17:44.430 To the best of your knowledge, 2429 02:17:44.430 --> 02:17:46.350 in fact the utility was permitted 2430 02:17:46.350 --> 02:17:48.920 to recover its exit financing cost in connection 2431 02:17:48.920 --> 02:17:51.000 with the previous bankruptcy, is that right? 2432 02:17:59.270 --> 02:18:01.653 It's my understanding that it was allowed 2433 02:18:01.653 --> 02:18:05.740 to recover the actual cost of the financing. 2434 02:18:07.918 --> 02:18:09.050 Let me move to another subject, 2435 02:18:09.050 --> 02:18:11.230 the regional restructuring. 2436 02:18:11.230 --> 02:18:14.200 As I understand it, you're supportive of PG&E's proposal 2437 02:18:14.200 --> 02:18:17.320 that it develop and implement a regional restructuring plan? 2438 02:18:19.690 --> 02:18:23.800 Yes, I made a similar recommendation actually 2439 02:18:23.800 --> 02:18:27.610 in my testimony that was submitted last year. 2440 02:18:28.980 --> 02:18:30.720 And in your opinion, such a restructuring 2441 02:18:30.720 --> 02:18:33.250 has strong potential to improve the quality 2442 02:18:33.250 --> 02:18:35.830 of PG&E's service to its customers, is that fair? 2443 02:18:38.440 --> 02:18:43.440 It has the potential to improve the quality of service 2444 02:18:43.690 --> 02:18:46.400 and the relationships that PG&E has 2445 02:18:46.400 --> 02:18:51.400 with the local communities and its customers 2446 02:18:51.470 --> 02:18:55.010 and I would say also its large customers. 2447 02:18:55.010 --> 02:18:57.240 And that regional restructuring in your view 2448 02:18:57.240 --> 02:18:59.310 would be beneficial to customers 2449 02:18:59.310 --> 02:19:02.170 even if PG&E had not filed for bankruptcy, right? 2450 02:19:07.500 --> 02:19:09.240 So you're saying hypothetically, 2451 02:19:09.240 --> 02:19:11.710 if we were sitting around thinking of ways 2452 02:19:11.710 --> 02:19:15.340 that we could improve PG&E's management, 2453 02:19:16.900 --> 02:19:20.490 regional restructuring would be on my, 2454 02:19:20.490 --> 02:19:23.960 are you asking if that would be on my list of to-dos? 2455 02:19:23.960 --> 02:19:26.320 As something that would be a positive, yes. 2456 02:19:28.410 --> 02:19:33.410 Yes, I think that, and I think I made it clear 2457 02:19:35.200 --> 02:19:40.200 in my testimony that PG&E went too far 2458 02:19:40.430 --> 02:19:44.893 when it consolidated itself in the early 2000s. 2459 02:19:47.490 --> 02:19:50.520 It was very focused on streamlining 2460 02:19:50.520 --> 02:19:54.220 and using measures of performance. 2461 02:19:54.220 --> 02:19:56.260 It just went too far. 2462 02:19:57.770 --> 02:20:00.710 There's certainly there are efficiencies in doing that, 2463 02:20:00.710 --> 02:20:04.720 but I think, if anything, overshot the mark 2464 02:20:04.720 --> 02:20:09.490 and have lost touch with what's going on in the regions. 2465 02:20:09.490 --> 02:20:11.940 And in your view, such a regional restructuring 2466 02:20:11.940 --> 02:20:14.010 would be sufficiently complicated, 2467 02:20:14.010 --> 02:20:15.930 that it would take a substantial amount of time 2468 02:20:15.930 --> 02:20:18.450 to create a fully fleshed out plan, is that fair? 2469 02:20:20.280 --> 02:20:24.030 There's a reason why my testimony recommends 2470 02:20:24.030 --> 02:20:29.030 that the reorganization be focused on the GRC, 2471 02:20:32.340 --> 02:20:36.020 which will be coming up and I mean the company 2472 02:20:36.020 --> 02:20:41.020 will be filing for the 2023 GRC in about a year. 2473 02:20:45.170 --> 02:20:49.070 In my experience, reorganizing, 2474 02:20:49.070 --> 02:20:54.070 I mean you've got 25,000 employees and you've got a lot 2475 02:20:54.970 --> 02:20:59.430 of different tasks that those employees are involved in. 2476 02:21:00.510 --> 02:21:04.720 It takes a lot of thought to figure out how you actually 2477 02:21:04.720 --> 02:21:08.910 are going to break apart what's been centralized 2478 02:21:08.910 --> 02:21:11.380 back into regional areas. 2479 02:21:12.280 --> 02:21:14.860 You don't want to do this badly. 2480 02:21:14.860 --> 02:21:17.730 That will make a bad problem worse. 2481 02:21:17.730 --> 02:21:18.890 You wanna do it well. 2482 02:21:19.880 --> 02:21:23.410 You wanna do it once and you wanna do it well. 2483 02:21:24.390 --> 02:21:29.390 And in my opinion it deserves the thought that's required 2484 02:21:30.200 --> 02:21:34.240 to do it well and the time that it takes 2485 02:21:34.240 --> 02:21:37.060 and the resources that it takes to do it well. 2486 02:21:37.060 --> 02:21:41.720 And then I think it will improve PG&E's performance. 2487 02:21:41.720 --> 02:21:43.810 Certainly will improve its interface 2488 02:21:43.810 --> 02:21:47.150 with the local communities. 2489 02:21:47.150 --> 02:21:49.180 Thank you, if you'll turn to page 15 2490 02:21:49.180 --> 02:21:50.480 of your testimony, please. 2491 02:21:51.380 --> 02:21:53.500 And I wanna direct you to lines 19 and 20. 2492 02:22:04.322 --> 02:22:05.420 You state there quote: 2493 02:22:05.420 --> 02:22:07.800 "The Commission should require PG&E 2494 02:22:07.800 --> 02:22:10.220 "to use shareholder funded research 2495 02:22:10.220 --> 02:22:13.640 "to better understand the concerns of its ratepayers 2496 02:22:13.640 --> 02:22:16.160 "in various parts of its large service territory." 2497 02:22:16.160 --> 02:22:16.993 Closed quote. 2498 02:22:16.993 --> 02:22:17.940 Do you see that? 2499 02:22:17.940 --> 02:22:18.800 Yes. 2500 02:22:18.800 --> 02:22:21.080 Isn't developing a robust understanding 2501 02:22:21.080 --> 02:22:22.650 of one's customers something 2502 02:22:22.650 --> 02:22:25.770 that should be a core part of a utility's operations? 2503 02:22:30.680 --> 02:22:32.380 Generally speaking, yes. 2504 02:22:32.380 --> 02:22:37.130 But I think in this situation PG&E needs to demonstrate 2505 02:22:37.130 --> 02:22:40.300 that its shareholders are committed 2506 02:22:40.300 --> 02:22:45.300 to really addressing the gap that has developed 2507 02:22:45.350 --> 02:22:50.350 between its communities, its customers, and its owners. 2508 02:22:50.510 --> 02:22:51.480 What's the, I am sorry. 2509 02:22:51.480 --> 02:22:52.313 Did I interrupt you? 2510 02:22:52.313 --> 02:22:53.450 Go ahead. 2511 02:22:53.450 --> 02:22:58.160 Yes, so that's the spirit within which this recommendation 2512 02:22:58.160 --> 02:23:03.160 is made in the context of the Plan of Reorganization. 2513 02:23:03.278 --> 02:23:06.110 Going forward I am not suggesting 2514 02:23:06.110 --> 02:23:10.490 that doing a certain amount of customer surveying 2515 02:23:10.490 --> 02:23:12.540 is something that should be disallowed 2516 02:23:12.540 --> 02:23:14.330 because it's an unreasonable cost. 2517 02:23:15.200 --> 02:23:16.800 What in your view is the principle 2518 02:23:16.800 --> 02:23:21.070 that divides utility activities that are part of rates, 2519 02:23:21.070 --> 02:23:23.670 versus things that should be funded by shareholders? 2520 02:23:31.360 --> 02:23:33.970 You're asking me that in a generic sense? 2521 02:23:33.970 --> 02:23:35.840 Well, you put this on side of the line. 2522 02:23:35.840 --> 02:23:38.540 I'm wondering what principle animates that conclusion? 2523 02:23:41.340 --> 02:23:43.910 I think I just expressed it. 2524 02:23:43.910 --> 02:23:48.910 That it's the circumstance that the company finds itself 2525 02:23:49.630 --> 02:23:54.630 in where the disconnect that's developed 2526 02:23:56.484 --> 02:23:59.130 between the company, its ownership, 2527 02:23:59.130 --> 02:24:02.450 its management and its customers, 2528 02:24:02.450 --> 02:24:07.450 I think it deserves, it deserves if you want, a gesture 2529 02:24:10.730 --> 02:24:14.280 that PG&E's owners and its management 2530 02:24:14.280 --> 02:24:18.380 is committed to really connecting with its customers. 2531 02:24:18.380 --> 02:24:20.750 And that it's not gonna ask its customers 2532 02:24:20.750 --> 02:24:24.610 to foot the bill for it to be bridging 2533 02:24:24.610 --> 02:24:27.950 that gap under these circumstances. 2534 02:24:27.950 --> 02:24:29.650 You're aware the Plan of Reorganization 2535 02:24:29.650 --> 02:24:32.050 involves some very, very substantial 2536 02:24:32.050 --> 02:24:35.220 shareholder funding of various things, correct? 2537 02:24:35.220 --> 02:24:36.053 Yes. 2538 02:24:39.110 --> 02:24:42.240 One could say the same thing as you just said 2539 02:24:42.240 --> 02:24:44.030 about any number of things that a utility 2540 02:24:44.030 --> 02:24:46.990 would ordinarily do that are good for its customers, 2541 02:24:46.990 --> 02:24:48.290 why is this one different? 2542 02:24:50.390 --> 02:24:52.280 Objection, your Honor, I believe this question 2543 02:24:52.280 --> 02:24:54.470 has been asked and answered more than once. 2544 02:24:54.470 --> 02:24:55.600 Sustained. 2545 02:24:58.420 --> 02:25:01.590 Let's talk about your discussion of rate neutrality. 2546 02:25:01.590 --> 02:25:04.490 You discussed that some in your testimony, correct? 2547 02:25:06.140 --> 02:25:08.230 There is a section of my testimony. 2548 02:25:08.230 --> 02:25:10.040 Would you like me to open it up? 2549 02:25:10.040 --> 02:25:11.450 Okay, yes. 2550 02:25:11.450 --> 02:25:13.440 I'm gonna direct you in a minute to page 21. 2551 02:25:13.440 --> 02:25:15.820 First, I have some more general questions. 2552 02:25:15.820 --> 02:25:17.920 Yes, you can turn to that now if you like. 2553 02:25:20.280 --> 02:25:23.730 In evaluating the neutral-on-average requirement 2554 02:25:23.730 --> 02:25:26.510 you understand that what is to be analyzed 2555 02:25:26.510 --> 02:25:29.310 is the rate impacts created by implementation 2556 02:25:29.310 --> 02:25:31.260 of the Plan of Reorganization, correct? 2557 02:25:32.180 --> 02:25:34.330 Yes, I kept that in mind. 2558 02:25:34.330 --> 02:25:36.060 So in evaluating rate neutrality, 2559 02:25:36.060 --> 02:25:38.480 you wouldn't think it appropriate to include 2560 02:25:38.480 --> 02:25:41.140 in rate impacts things that would have happened 2561 02:25:41.140 --> 02:25:43.590 without the bankruptcy reorganization, would you? 2562 02:25:45.230 --> 02:25:50.230 In my analysis, I focused on the incremental costs, 2563 02:25:52.420 --> 02:25:55.900 if you will, or the, actually, the Plan of Reorganization 2564 02:25:55.900 --> 02:26:00.900 doesn't propose costs per se except for the financing. 2565 02:26:03.100 --> 02:26:05.030 So I focused on that. 2566 02:26:05.030 --> 02:26:08.180 So, it's an incremental analysis understanding 2567 02:26:08.180 --> 02:26:10.650 that there is other things that are going on. 2568 02:26:12.240 --> 02:26:14.860 So I think the incremental analysis you're referring 2569 02:26:14.860 --> 02:26:18.880 to is summarized at page 21, well, 2570 02:26:18.880 --> 02:26:20.350 I won't put words in your mouth. 2571 02:26:20.350 --> 02:26:25.350 If you turn to page 21, lines 14 to 19, it states, quote: 2572 02:26:32.480 --> 02:26:35.550 "However, if the Commission were to permit PG&E 2573 02:26:35.550 --> 02:26:38.330 "to recover any professional fees and expenses 2574 02:26:38.330 --> 02:26:41.210 "associated with the Chapter 11 proceedings, 2575 02:26:41.210 --> 02:26:43.360 "the Commission would have to limit the recovery 2576 02:26:43.360 --> 02:26:46.040 "of those fees and expenses and require them 2577 02:26:46.040 --> 02:26:49.230 "to be amortized over a long period of time 2578 02:26:49.230 --> 02:26:53.070 "to ensure that the combination of the professional fees 2579 02:26:53.070 --> 02:26:55.270 "and debt costs do not exceed 2580 02:26:55.270 --> 02:26:58.020 "the 70.7 million dollar reduction 2581 02:26:58.020 --> 02:26:59.890 "in debt costs in any given year." 2582 02:27:01.041 --> 02:27:01.874 Do you see that? 2583 02:27:01.874 --> 02:27:03.064 Yes. 2584 02:27:03.064 --> 02:27:05.870 And if I understand your testimony, 2585 02:27:05.870 --> 02:27:08.770 you are not asserting in your testimony 2586 02:27:08.770 --> 02:27:12.470 that PG&E's plan fails to satisfy AB-1054's 2587 02:27:12.470 --> 02:27:15.147 neutral-on-average requirement, right? 2588 02:27:18.003 --> 02:27:23.003 I haven't come to that conclusion per se. 2589 02:27:23.160 --> 02:27:27.520 I have discussed some circumstances 2590 02:27:27.520 --> 02:27:31.570 under which it could violate that provision. 2591 02:27:32.440 --> 02:27:36.170 And fair to say if PG&E, strike that. 2592 02:27:37.300 --> 02:27:41.523 On the other hand, if PG&E's plan, strike that. 2593 02:27:43.630 --> 02:27:44.463 Bad question. 2594 02:27:44.463 --> 02:27:48.640 Fair to say you agree that PG&E's plan would satisfy AB-1054 2595 02:27:48.640 --> 02:27:50.620 neutral-on-average requirement 2596 02:27:50.620 --> 02:27:53.660 so long as the costs PG&E seeks to recover 2597 02:27:53.660 --> 02:27:56.290 in connection with that plan do not 2598 02:27:56.290 --> 02:27:58.940 exceed the interest cost savings created by the plan? 2599 02:28:03.790 --> 02:28:08.133 Yes, if you're generating 70.7 million 2600 02:28:10.830 --> 02:28:14.660 in revenue for a period of time, a revenue reduction 2601 02:28:14.660 --> 02:28:19.660 for a period of time, you can't impose costs 2602 02:28:22.450 --> 02:28:25.270 in any given year through rates. 2603 02:28:25.270 --> 02:28:29.510 You can amortize a cost in a current period 2604 02:28:29.510 --> 02:28:34.050 over a long period of time to reduce it such 2605 02:28:34.050 --> 02:28:39.050 that it would not exceed 70.7 million per year 2606 02:28:39.370 --> 02:28:44.370 for the period of time where there are debt savings 2607 02:28:45.500 --> 02:28:50.200 and it would remain neutral under those circumstances. 2608 02:28:51.470 --> 02:28:55.370 Did you review the clarification document 2609 02:28:55.370 --> 02:28:57.660 submitted by PG&E at the beginning of these hearings 2610 02:28:57.660 --> 02:29:00.020 that was marked as PG&E Exhibit Eight? 2611 02:29:01.420 --> 02:29:03.510 Yes, I have looked at that spreadsheet. 2612 02:29:03.510 --> 02:29:05.370 Would you like me to open it? 2613 02:29:05.370 --> 02:29:06.910 I think it's in front of you. 2614 02:29:06.910 --> 02:29:09.250 It's actually, I'm not referring to a spreadsheet. 2615 02:29:09.250 --> 02:29:11.720 I'm referring to the actual 2616 02:29:11.720 --> 02:29:14.360 clarification document, Exhibit Eight. 2617 02:29:15.280 --> 02:29:17.120 Oh, okay, I'm sorry, I was thinking -- 2618 02:29:17.120 --> 02:29:18.431 No, that's fine. 2619 02:29:18.431 --> 02:29:19.264 A different document. 2620 02:29:19.264 --> 02:29:21.040 Yes, no I have read this, yes. 2621 02:29:22.860 --> 02:29:25.640 And if you look at the first clarification there, 2622 02:29:25.640 --> 02:29:30.190 paragraph one, which I'll summarize 2623 02:29:30.190 --> 02:29:33.040 but if you feel I'm summarizing incorrectly, let me know, 2624 02:29:34.570 --> 02:29:39.570 limits the professional fees that PG&E seeks 2625 02:29:40.070 --> 02:29:44.970 to recover to the financing-related fees. 2626 02:29:46.340 --> 02:29:50.330 And it estimates those at about 154 million, correct? 2627 02:29:59.640 --> 02:30:01.170 Yes, that is correct. 2628 02:30:01.170 --> 02:30:03.420 And so subject to that clarification, 2629 02:30:03.420 --> 02:30:06.340 would you agree that so long as those financing fees 2630 02:30:06.340 --> 02:30:09.370 are amortized over the length of the debt, 2631 02:30:09.370 --> 02:30:12.270 PG&E's plan would satisfy the rate neutrality requirement? 2632 02:30:13.740 --> 02:30:16.660 Yes, I did a calculation not using 2633 02:30:16.660 --> 02:30:19.500 exactly the same figures, but I demonstrated 2634 02:30:19.500 --> 02:30:23.430 that you could satisfy the rate neutrality 2635 02:30:23.430 --> 02:30:26.940 by amortizing approximately that amount of money. 2636 02:30:30.233 --> 02:30:32.540 If you'll turn to your testimony at page 17. 2637 02:30:44.570 --> 02:30:48.200 The last two lines on that page you state, quote: 2638 02:30:48.200 --> 02:30:51.110 "If one uses a more appropriate discount rate 2639 02:30:51.110 --> 02:30:54.200 "of 8% which is reflective of the cost 2640 02:30:54.200 --> 02:30:58.270 "of money for PG&E's investors as well as its ratepayers." 2641 02:30:59.380 --> 02:31:02.530 And then it goes on from there to give the calculation. 2642 02:31:03.412 --> 02:31:04.780 Do you see where I'm reading from? 2643 02:31:04.780 --> 02:31:06.150 Yes, I do. 2644 02:31:06.150 --> 02:31:11.150 And footnote 49 in your testimony at the end 2645 02:31:13.480 --> 02:31:17.080 of that sentence states that PG&E's 2020 2646 02:31:17.080 --> 02:31:20.310 adopted cost of capital is 7.81%. 2647 02:31:21.447 --> 02:31:22.280 Do you see that? 2648 02:31:28.250 --> 02:31:29.083 Yes. 2649 02:31:29.083 --> 02:31:30.930 And so when you use 8% in the body, 2650 02:31:30.930 --> 02:31:33.060 you're not asserting some different discount rate, 2651 02:31:33.060 --> 02:31:35.280 you're just rounding, is that fair? 2652 02:31:35.280 --> 02:31:40.280 I actually was using it as a representative of the 7.8, 2653 02:31:41.050 --> 02:31:45.450 but also putting it in perspective for ratepayers and I, 2654 02:31:45.450 --> 02:31:49.230 in my previous footnote had discussed the fact 2655 02:31:49.230 --> 02:31:53.310 that people are earning rather low interest rates 2656 02:31:53.310 --> 02:31:55.290 on their savings accounts, 2657 02:31:55.290 --> 02:31:59.370 but at the same time they face very high borrowing costs, 2658 02:31:59.370 --> 02:32:02.070 particularly if they're relying on credit cards. 2659 02:32:02.070 --> 02:32:06.020 So, I was kind of doing a, you know, here's a span, 2660 02:32:06.020 --> 02:32:10.260 here's a range and 8% is kind of in the middle. 2661 02:32:10.260 --> 02:32:15.040 It's representative of the utility's cost of capital, 2662 02:32:15.040 --> 02:32:18.980 so I felt it was a good number to use as a discount rate. 2663 02:32:21.830 --> 02:32:26.830 Why do you think 8% or 7.81% is a better percentage 2664 02:32:28.050 --> 02:32:29.410 to use for purposes of thinking 2665 02:32:29.410 --> 02:32:34.410 about rate neutrality than the 4.7-odd percentage 2666 02:32:35.880 --> 02:32:37.730 referenced earlier in that testimony? 2667 02:32:39.460 --> 02:32:44.420 Well, we could read my footnote 48, which says: 2668 02:32:44.420 --> 02:32:48.030 "Discount rates reflect the underlying time value 2669 02:32:48.030 --> 02:32:51.230 "of money and should do so for ratepayers 2670 02:32:51.230 --> 02:32:53.420 "as well as investors. 2671 02:32:53.420 --> 02:32:55.780 "The time value of money for ordinary people 2672 02:32:55.780 --> 02:32:59.300 "can range from relatively low rates 2673 02:32:59.300 --> 02:33:01.830 "that people can earn on bank savings accounts 2674 02:33:01.830 --> 02:33:05.830 "to very high discount rates such as 16 to 18% 2675 02:33:05.830 --> 02:33:08.040 "that is reflective of their actual short-term 2676 02:33:08.040 --> 02:33:11.050 "costs of borrowing, for example, credit cards. 2677 02:33:11.050 --> 02:33:14.350 "The 8% that I used in my analysis is reflective 2678 02:33:14.350 --> 02:33:16.940 "of utility investor's cost of money 2679 02:33:16.940 --> 02:33:19.670 "and also falls well within the range 2680 02:33:19.670 --> 02:33:22.630 "that could be considered appropriate for ratepayers." 2681 02:33:24.210 --> 02:33:27.540 In using that 8% figure, you calculated interest rate 2682 02:33:27.540 --> 02:33:31.580 savings under the PG&E plan of 694 million, correct? 2683 02:33:31.580 --> 02:33:36.580 Right, that was assuming that it was a 20-year period. 2684 02:33:36.710 --> 02:33:39.620 And in calculating that discounted amount, 2685 02:33:39.620 --> 02:33:43.600 you started discounting in year one in your calculation? 2686 02:33:43.600 --> 02:33:44.970 At the end of year one, yes. 2687 02:33:44.970 --> 02:33:46.180 So you would agree we'd also have 2688 02:33:46.180 --> 02:33:49.000 to start discounting in year one 2689 02:33:49.000 --> 02:33:53.370 the corresponding financing costs that are amortized? 2690 02:33:57.680 --> 02:34:00.570 I used a net present value calculation 2691 02:34:00.570 --> 02:34:05.570 and had zero as the cost, which is generally net present 2692 02:34:07.140 --> 02:34:10.950 value calculations do things at the beginning of the period. 2693 02:34:10.950 --> 02:34:13.400 You could make it do everything at the end. 2694 02:34:17.230 --> 02:34:21.840 Let me have you turn to the spreadsheet that, 2695 02:34:21.840 --> 02:34:26.090 let me take ALJ Allen's advice and give it the agreed title, 2696 02:34:27.970 --> 02:34:31.010 the spreadsheet that you identified earlier, 2697 02:34:31.010 --> 02:34:33.720 I think we called it, Cost of Debt Detail. 2698 02:34:45.030 --> 02:34:46.760 And that's a multi-page document? 2699 02:34:46.760 --> 02:34:47.673 Yes, your Honor. 2700 02:34:53.342 --> 02:34:55.030 Cost of Detail, got it. 2701 02:34:55.030 --> 02:34:56.640 Before we get into the details there, 2702 02:34:56.640 --> 02:35:00.290 I just wanna understand, let's take a step back. 2703 02:35:00.290 --> 02:35:03.450 Am I correct in understanding you have no disagreement 2704 02:35:03.450 --> 02:35:06.310 that 4.3% is a reasonable estimate 2705 02:35:06.310 --> 02:35:09.660 of the post-emergence cost of debt under PG&E's plan? 2706 02:35:15.700 --> 02:35:18.670 I preserved PG&E's calculation 2707 02:35:18.670 --> 02:35:21.600 on the right-hand side of the first page 2708 02:35:21.600 --> 02:35:24.990 and that, I have no disagreement with that calculation. 2709 02:35:26.950 --> 02:35:31.620 And then in your rework, and we'll get into the details 2710 02:35:31.620 --> 02:35:34.090 of that, at the end of the rework, 2711 02:35:34.090 --> 02:35:38.040 you're showing net savings after offsetting financial fees 2712 02:35:38.040 --> 02:35:40.070 and underwriting fees and whatnot, 2713 02:35:40.070 --> 02:35:43.160 net savings of nine million per year, is that correct? 2714 02:35:45.350 --> 02:35:50.210 That's the difference between the 183 2715 02:35:50.210 --> 02:35:53.230 that you calculate from the first set of figures. 2716 02:35:53.230 --> 02:35:56.370 Now, you ask yourself, why did I calculate 2717 02:35:56.370 --> 02:35:58.000 that first set of figures? 2718 02:35:59.010 --> 02:36:03.630 It's because that's the cost of debt 2719 02:36:04.620 --> 02:36:09.260 if we don't have the rate, the interest rate reduction, 2720 02:36:10.820 --> 02:36:15.807 that the POR proposes or accomplishes. 2721 02:36:17.870 --> 02:36:22.870 So you end up with a 4.35% cost of debt absent 2722 02:36:25.260 --> 02:36:29.490 that change that the POR brings. 2723 02:36:30.510 --> 02:36:31.970 I was trying to isolate. 2724 02:36:33.050 --> 02:36:35.100 And the net result of that isolation 2725 02:36:35.100 --> 02:36:37.810 in your calculation is a savings 2726 02:36:37.810 --> 02:36:39.460 of nine million dollars per year? 2727 02:36:40.680 --> 02:36:43.350 Yes, and the reason for that is 2728 02:36:43.350 --> 02:36:48.150 because the fees cost you a lot of money. 2729 02:36:49.806 --> 02:36:53.510 Now we're looking at 2021, the fees are 2730 02:36:53.510 --> 02:36:57.260 basically drinking up everything except the nine million 2731 02:36:58.360 --> 02:37:03.360 in the 70.9 million dollar reduction in interest rate costs 2732 02:37:08.140 --> 02:37:11.320 most of it's been drunk up by the fees. 2733 02:37:11.320 --> 02:37:16.320 Now, PG&E posited that we should compare the 4.3, 2734 02:37:21.920 --> 02:37:26.920 it's actually 4.31% interest rate that comes out 2735 02:37:27.540 --> 02:37:29.420 of the Plan of Reorganization, 2736 02:37:29.420 --> 02:37:32.500 which I have no disagreements with that, 2737 02:37:32.500 --> 02:37:36.000 that's post the reduction in interest rates, 2738 02:37:36.000 --> 02:37:39.840 that we should compare that with the 5.16 2739 02:37:39.840 --> 02:37:44.450 that was adopted in the cost capital decision for 2020. 2740 02:37:44.450 --> 02:37:48.310 The problem with doing that is that was a number-- 2741 02:37:48.310 --> 02:37:49.880 I think you're getting well beyond my question. 2742 02:37:49.880 --> 02:37:54.530 Yeah, well, that was a number that was forecasted, okay. 2743 02:37:54.530 --> 02:37:57.570 So it has to do with attribution 2744 02:37:57.570 --> 02:38:01.010 and that's why we ended up with two sets of numbers. 2745 02:38:01.010 --> 02:38:02.900 And I do wanna go through this in some detail, 2746 02:38:02.900 --> 02:38:04.970 but just step by step, please. 2747 02:38:05.870 --> 02:38:10.220 So if we look at the upper left here, 2748 02:38:11.650 --> 02:38:15.430 pre-petition debt amortization, you say, 2749 02:38:15.430 --> 02:38:18.520 "No fees if no RSA renegotiation." 2750 02:38:18.520 --> 02:38:19.600 Do you see that? 2751 02:38:19.600 --> 02:38:20.433 Yes. 2752 02:38:20.433 --> 02:38:24.460 Now, in fact, there were fees incurred by PG&E 2753 02:38:24.460 --> 02:38:26.350 on pre-petition debt, correct? 2754 02:38:30.460 --> 02:38:31.430 Originally. 2755 02:38:31.430 --> 02:38:35.500 You mean when the debt was originally financed? 2756 02:38:35.500 --> 02:38:37.650 And aren't those fees amortized over the course 2757 02:38:37.650 --> 02:38:38.483 of the debt? 2758 02:38:41.970 --> 02:38:43.270 They may be. 2759 02:38:43.270 --> 02:38:44.190 But you haven't added them 2760 02:38:44.190 --> 02:38:45.810 to the average coupon in your number, 2761 02:38:45.810 --> 02:38:47.410 in your recalculation, have you? 2762 02:38:48.470 --> 02:38:50.610 No, but PG&E didn't add them 2763 02:38:50.610 --> 02:38:53.680 to their calculation either, so-- 2764 02:38:53.680 --> 02:38:55.890 Look on the right-hand side, it is added there. 2765 02:38:55.890 --> 02:39:00.510 The pre-petition debt amortization 0.15% is there, isn't it? 2766 02:39:04.200 --> 02:39:05.800 Okay, you are correct. 2767 02:39:05.800 --> 02:39:08.390 I should have left the 0.15 in there. 2768 02:39:11.560 --> 02:39:14.220 And then in the next line, underwriting fees 2769 02:39:14.220 --> 02:39:18.590 on 5.925 billion of new issue. 2770 02:39:19.890 --> 02:39:23.480 PG&E had long and short-term debt authorization 2771 02:39:23.480 --> 02:39:26.080 requests pending when it declared bankruptcy, right? 2772 02:39:30.410 --> 02:39:31.780 I'm not sure. 2773 02:39:31.780 --> 02:39:33.290 Well, putting aside the details, 2774 02:39:33.290 --> 02:39:35.750 certainly you would understand that rate base was growing 2775 02:39:35.750 --> 02:39:38.790 and PG&E would have needed to issue new debt 2776 02:39:38.790 --> 02:39:42.080 regardless of bankruptcy, right? 2777 02:39:42.080 --> 02:39:46.280 I'm generally aware that PG&E has the need 2778 02:39:46.280 --> 02:39:51.280 to issue debt and potentially stock periodically. 2779 02:39:51.560 --> 02:39:54.730 And customarily that would involve underwriting, right? 2780 02:39:55.990 --> 02:39:56.880 Yes. 2781 02:39:56.880 --> 02:39:59.640 And on the right-hand side here, 2782 02:40:00.646 --> 02:40:04.900 you have a 0.02% for the underwriting fees 2783 02:40:04.900 --> 02:40:06.600 on that amount of new debt, right? 2784 02:40:11.220 --> 02:40:12.681 Yes, I do. 2785 02:40:12.681 --> 02:40:14.200 And there would be some corresponding, 2786 02:40:14.200 --> 02:40:16.670 roughly corresponding, number that would 2787 02:40:16.670 --> 02:40:18.510 be incurred for the new debt 2788 02:40:18.510 --> 02:40:20.910 if it was incurred outside of bankruptcy, right? 2789 02:40:36.349 --> 02:40:40.182 Let me just see if this is included in here. 2790 02:40:45.660 --> 02:40:49.890 No, you're correct because it is included in the column. 2791 02:40:49.890 --> 02:40:51.320 Thanks. 2792 02:40:51.320 --> 02:40:53.269 Stepping back from the details, 2793 02:40:53.269 --> 02:40:54.510 let's just think of a sort of a gestalt way 2794 02:40:54.510 --> 02:40:55.343 to think about this. 2795 02:40:55.343 --> 02:40:57.610 You understand that Southern California Edison's 2796 02:40:57.610 --> 02:41:00.870 current authorized cost of debt rising out 2797 02:41:00.870 --> 02:41:05.030 of the cost of capital proceeding is 4.74%. 2798 02:41:05.030 --> 02:41:05.930 Sound about right? 2799 02:41:08.940 --> 02:41:12.270 I haven't looked at their cost of capital recently. 2800 02:41:13.410 --> 02:41:15.740 Putting aside the exact number, you wouldn't suggest 2801 02:41:15.740 --> 02:41:18.310 that without the bankruptcy reorganization, 2802 02:41:18.310 --> 02:41:21.210 PG&E would have had a lower cost of debt 2803 02:41:21.210 --> 02:41:25.900 than Southern California Edison, would you? 2804 02:41:27.170 --> 02:41:28.720 I'm not suggesting anything. 2805 02:41:28.720 --> 02:41:31.080 I was just working the math given-- 2806 02:41:31.080 --> 02:41:32.470 But would you agree, and I'm trying to, 2807 02:41:32.470 --> 02:41:34.480 I'm sorry, I interrupted you, go ahead. 2808 02:41:34.480 --> 02:41:37.850 I mean I worked the math basically. 2809 02:41:37.850 --> 02:41:40.040 I had, the data was available. 2810 02:41:41.510 --> 02:41:46.510 I went and I replaced the exchanged debt 2811 02:41:46.920 --> 02:41:51.920 with the old exchanged debt, so with the old interest rates 2812 02:41:52.500 --> 02:41:54.200 to bring it up to the higher amount. 2813 02:41:54.200 --> 02:41:57.810 So I'm, to the extent that PG&E said 2814 02:41:57.810 --> 02:42:02.810 that 4.31% was the correct cost of debt as compared 2815 02:42:02.930 --> 02:42:06.950 to the 5.16 in a cost of capital case, 2816 02:42:06.950 --> 02:42:10.180 all I did was an incremental analysis. 2817 02:42:10.180 --> 02:42:12.900 And I apologize, I probably should 2818 02:42:12.900 --> 02:42:16.490 have picked up a few hundredths it looks like 2819 02:42:16.490 --> 02:42:19.310 or maybe a 0.2%. 2820 02:42:20.360 --> 02:42:21.640 That's my mistake. 2821 02:42:22.790 --> 02:42:25.890 That would have raised the resulting cost 2822 02:42:25.890 --> 02:42:28.940 of capital to 4.5 maybe. 2823 02:42:28.940 --> 02:42:33.320 But the point here is I was trying to do a parallel analysis 2824 02:42:33.320 --> 02:42:38.320 so we can isolate the effect of the POR 2825 02:42:38.520 --> 02:42:43.520 and not the forecast error, or the forecast uncertainty. 2826 02:42:43.630 --> 02:42:45.632 Ms. Yap, I don't think there's 2827 02:42:45.632 --> 02:42:46.640 that question pending. 2828 02:42:46.640 --> 02:42:49.090 Mr. Allred, if you could ask your next question. 2829 02:42:49.090 --> 02:42:50.300 Ms. Yap, if you could make sure 2830 02:42:50.300 --> 02:42:53.210 that you're answering the question. 2831 02:42:53.210 --> 02:42:55.964 If you want more explanation to provide, 2832 02:42:55.964 --> 02:42:58.280 you can do that on redirect. 2833 02:42:58.280 --> 02:42:59.648 Mr. Allred. 2834 02:42:59.648 --> 02:43:00.481 Thank you, your Honor. 2835 02:43:00.481 --> 02:43:03.530 And I'm just asking independent of your calculation, 2836 02:43:03.530 --> 02:43:05.963 sometimes its useful to step back, 2837 02:43:05.963 --> 02:43:08.190 but before you dive into or after you try 2838 02:43:08.190 --> 02:43:11.370 to dive into the details of a complicated spreadsheet 2839 02:43:11.370 --> 02:43:15.870 and say, does this result seem consistent 2840 02:43:15.870 --> 02:43:17.290 with what one would expect 2841 02:43:17.290 --> 02:43:19.250 from a big-picture look at things? 2842 02:43:19.250 --> 02:43:24.250 You would not expect a pre-bankruptcy or non-bankruptcy PG&E 2843 02:43:24.660 --> 02:43:27.900 to have a lower cost of debt 2844 02:43:27.900 --> 02:43:29.710 than Southern California Edison, would you? 2845 02:43:29.710 --> 02:43:30.850 Objection, your Honor. 2846 02:43:30.850 --> 02:43:33.240 Ms. Yap has indicated that she is not familiar 2847 02:43:33.240 --> 02:43:35.770 with Southern California's cost of debt. 2848 02:43:35.770 --> 02:43:37.730 Overruled, it's a general question. 2849 02:43:41.570 --> 02:43:44.450 I would expect it to be generally similar, 2850 02:43:45.830 --> 02:43:48.830 but there are differences between the companies, 2851 02:43:48.830 --> 02:43:51.590 so, within the same ballpark, 2852 02:43:53.630 --> 02:43:56.820 assuming that PG&E was not in bankruptcy. 2853 02:44:10.420 --> 02:44:13.200 So if we were to take just the two changes 2854 02:44:13.200 --> 02:44:18.200 that you have noted of adding in the roughly 0.2%, 2855 02:44:18.980 --> 02:44:20.590 that would take the savings back 2856 02:44:20.590 --> 02:44:23.753 to over 40 million a year in 2021, right? 2857 02:44:31.510 --> 02:44:33.220 I can work the spread sheet 2858 02:44:33.220 --> 02:44:35.500 if you wanna ask that question. 2859 02:44:35.500 --> 02:44:38.000 I can't tell just off the top 2860 02:44:38.000 --> 02:44:39.830 of my head looking at the numbers. 2861 02:44:49.970 --> 02:44:52.690 But it would certainly change the 183. 2862 02:44:52.690 --> 02:44:55.810 I'm willing to agree with that, that the result 2863 02:44:55.810 --> 02:45:00.810 of increasing the 4.35% and you compare it to 5.16 2864 02:45:04.220 --> 02:45:07.280 and then you take the difference times the rate base, 2865 02:45:07.280 --> 02:45:10.260 that's gonna give you a lower number than 1.83. 2866 02:45:13.200 --> 02:45:17.460 And do you have any quarrel with the approach 2867 02:45:17.460 --> 02:45:20.400 of taking the revenue requirements 2868 02:45:20.400 --> 02:45:23.660 and applying these percentages to calculate savings? 2869 02:45:25.920 --> 02:45:28.280 I'm sorry, can you ask that question again, please? 2870 02:45:28.280 --> 02:45:30.530 The basic structure of this spreadsheet 2871 02:45:30.530 --> 02:45:35.530 is taking the coupon and the fees, 2872 02:45:37.690 --> 02:45:39.730 calculating the difference from the authorized cost 2873 02:45:39.730 --> 02:45:44.290 of debt and applying that to the revenue requirements 2874 02:45:44.290 --> 02:45:45.980 to get a revenue requirement savings, correct? 2875 02:45:48.540 --> 02:45:52.750 In my response to PG&E's data request, 2876 02:45:52.750 --> 02:45:57.750 I agreed that mathematically you take the incremental change 2877 02:45:59.720 --> 02:46:04.520 in debt times the capital share represented 2878 02:46:04.520 --> 02:46:07.080 by debt times the rate base, 2879 02:46:07.080 --> 02:46:10.700 you do end up with a revenue requirement impact. 2880 02:46:10.700 --> 02:46:12.020 I agree with that. 2881 02:46:12.020 --> 02:46:15.305 There's no math error in PG&E's calculation 2882 02:46:15.305 --> 02:46:20.305 that based on a 0.85% reduction in the cost of capital, 2883 02:46:21.370 --> 02:46:25.430 you would get 192 million dollar a year savings, right? 2884 02:46:25.430 --> 02:46:29.980 Again, in the response to PG&E's questions, 2885 02:46:29.980 --> 02:46:34.980 I did agree that mathematically you derive 192 million. 2886 02:46:35.620 --> 02:46:40.620 I just didn't agree with the attribution of that 0.85 2887 02:46:43.800 --> 02:46:46.850 to the POR because I don't think that's correct. 2888 02:46:50.888 --> 02:46:52.288 If you'll turn to page 23. 2889 02:47:07.180 --> 02:47:09.048 At the top of that page you say, quote: 2890 02:47:09.048 --> 02:47:12.600 "While I appreciate the fact that securitizing debt 2891 02:47:12.600 --> 02:47:16.350 "has the potential to improve PG&E's credit rating 2892 02:47:16.350 --> 02:47:20.090 "and correspondingly reduce overall debt costs, 2893 02:47:20.090 --> 02:47:23.190 "in my opinion the risk of securitization 2894 02:47:23.190 --> 02:47:24.560 "is too great." 2895 02:47:24.560 --> 02:47:25.393 Close quote. 2896 02:47:25.393 --> 02:47:26.400 Do you see that? 2897 02:47:26.400 --> 02:47:28.290 Yes, I did write that sentence. 2898 02:47:28.290 --> 02:47:32.270 And you agree that securitization does provide benefits? 2899 02:47:32.270 --> 02:47:35.870 There is a positive side of the ledger to securitization? 2900 02:47:35.870 --> 02:47:40.870 It moves debt off of the balance sheet effectively. 2901 02:47:41.700 --> 02:47:44.400 And provides for a lower cost finance source; right? 2902 02:47:45.410 --> 02:47:47.740 That's the theory, that is, 2903 02:47:47.740 --> 02:47:52.297 you clean up the balance sheet, you improve the look 2904 02:47:54.510 --> 02:47:58.400 to the rating agencies and the hope is that they improve. 2905 02:47:58.400 --> 02:48:00.870 And also strictly within the securitization 2906 02:48:00.870 --> 02:48:02.120 you can get a lower rate, 2907 02:48:02.120 --> 02:48:04.470 because of the securitization structure, right? 2908 02:48:06.610 --> 02:48:09.480 I'm sorry, ask the question one more time, please. 2909 02:48:09.480 --> 02:48:11.840 By using a securitization structure, 2910 02:48:11.840 --> 02:48:14.260 one can get a lower interest rate 2911 02:48:14.260 --> 02:48:16.990 than through other types of debt? 2912 02:48:16.990 --> 02:48:20.040 For the, you're talking about for the seven billion 2913 02:48:20.040 --> 02:48:23.920 that PG&E is requesting the securitization for? 2914 02:48:23.920 --> 02:48:26.870 Right, or for whatever amount, right 2915 02:48:26.870 --> 02:48:28.420 Not whatever amount, but for whatever amount 2916 02:48:28.420 --> 02:48:31.390 you're securitizing, you can get 2917 02:48:31.390 --> 02:48:34.400 that debt at a lower cost by securitizing. 2918 02:48:34.400 --> 02:48:37.280 Yes, because you do have the guarantee 2919 02:48:37.280 --> 02:48:39.000 of the stream of money. 2920 02:48:39.000 --> 02:48:39.890 And that can translate 2921 02:48:39.890 --> 02:48:41.740 into ratepayer benefits, fair to say? 2922 02:48:44.120 --> 02:48:45.920 It depends on whether you think 2923 02:48:45.920 --> 02:48:50.490 that the ratepayers should be paying that stream of money. 2924 02:48:51.510 --> 02:48:54.840 In other words, if you think that the ratepayers are obliged 2925 02:48:54.840 --> 02:48:58.320 to pay the seven billion, then securitizing it 2926 02:48:58.320 --> 02:49:01.250 would offer them a lower cost of debt 2927 02:49:02.090 --> 02:49:04.500 for paying that seven billion. 2928 02:49:04.500 --> 02:49:07.445 But it remains, in my mind, a question 2929 02:49:07.445 --> 02:49:09.610 as to whether the ratepayer 2930 02:49:09.610 --> 02:49:12.040 should be paying the seven billion. 2931 02:49:12.040 --> 02:49:16.080 And therein lies the rub from a policy perspective. 2932 02:49:16.080 --> 02:49:19.290 Now, the reason you expressed concern is because of risk. 2933 02:49:19.290 --> 02:49:20.570 Is the risk you're referring 2934 02:49:20.570 --> 02:49:23.500 to another possible PG&E bankruptcy? 2935 02:49:24.680 --> 02:49:25.720 Yes. 2936 02:49:25.720 --> 02:49:28.170 And do you believe the Commission has the authority 2937 02:49:28.170 --> 02:49:31.310 to order that rate credits proposed by PG&E 2938 02:49:31.310 --> 02:49:35.020 to offset the non-bypassable rate charges 2939 02:49:35.020 --> 02:49:38.240 for the proposed securitization would continue 2940 02:49:38.240 --> 02:49:41.240 in the event PG&E were to file for bankruptcy in the future? 2941 02:49:42.890 --> 02:49:45.580 You need to repeat the question, please. 2942 02:49:45.580 --> 02:49:48.680 Does this Commission have the authority to order 2943 02:49:48.680 --> 02:49:53.340 that rate credits that would be used as an offset 2944 02:49:53.340 --> 02:49:58.340 in a securitization to the rate charges would continue 2945 02:49:58.710 --> 02:50:02.900 in the event of a PG&E bankruptcy? 2946 02:50:02.900 --> 02:50:04.560 You know, I don't know. 2947 02:50:04.560 --> 02:50:07.260 I think that remains an open question as 2948 02:50:07.260 --> 02:50:10.970 to whether they would have that authority if PG&E were 2949 02:50:10.970 --> 02:50:12.810 to declare bankruptcy again. 2950 02:50:12.810 --> 02:50:15.000 If the Commission were to determine it did have 2951 02:50:15.000 --> 02:50:16.660 that authority, that would reassure you 2952 02:50:16.660 --> 02:50:18.410 on the risk that you cite, correct? 2953 02:50:19.860 --> 02:50:23.170 It would certainly address an issue. 2954 02:50:24.110 --> 02:50:25.860 It's the issue you've identified. 2955 02:50:26.810 --> 02:50:31.260 I've identified another issue as well, the concern 2956 02:50:31.260 --> 02:50:33.510 that the ratepayers, I mean if we wanna read 2957 02:50:33.510 --> 02:50:37.450 on in my testimony, the concern that the ratepayers feel 2958 02:50:37.450 --> 02:50:40.490 like maybe this isn't a cost that they ought 2959 02:50:40.490 --> 02:50:43.650 to be paying and that the Commission 2960 02:50:43.650 --> 02:50:48.370 hasn't addressed whether it's reasonable for them to pay it. 2961 02:50:49.980 --> 02:50:52.300 Assuming that the securitization is structured 2962 02:50:52.300 --> 02:50:54.390 to be rate neutrality with offsets, 2963 02:50:54.390 --> 02:50:57.060 and we'll discuss what those offsets are, 2964 02:50:57.060 --> 02:51:01.350 assuming that it's structured to be neutral to ratepayers, 2965 02:51:01.350 --> 02:51:02.950 that issue would go away, right? 2966 02:51:04.600 --> 02:51:09.600 If the Commission could somehow guarantee that those, 2967 02:51:12.720 --> 02:51:17.720 and I'm not, and in my opinion, I'm not convinced 2968 02:51:17.910 --> 02:51:22.910 that the Commission could do that, but hypothetically, 2969 02:51:23.130 --> 02:51:27.180 if the Commission were able to guarantee that 2970 02:51:27.180 --> 02:51:32.180 that stream of payments from PG&E would go forward 2971 02:51:34.050 --> 02:51:36.920 for the entire life of the securitization, 2972 02:51:40.260 --> 02:51:42.030 bankruptcy or no bankruptcy, 2973 02:51:43.530 --> 02:51:46.750 regardless of whatever liabilities PG&E might face 2974 02:51:46.750 --> 02:51:50.690 in the future, then, yes, that would address a concern. 2975 02:51:51.980 --> 02:51:56.650 Then I wanna now have you turn to PG&E-X-02, 2976 02:51:56.650 --> 02:51:58.090 which is another data request, 2977 02:51:58.090 --> 02:51:59.740 it's a one-pager in front of you. 2978 02:52:13.091 --> 02:52:14.960 Do you have that in front of you? 2979 02:52:14.960 --> 02:52:18.219 That's the six, seven, and eight? 2980 02:52:18.219 --> 02:52:20.317 Question six, seven and eight? 2981 02:52:20.317 --> 02:52:21.973 Okay. 2982 02:52:21.973 --> 02:52:23.860 And in the response to Q6, the second 2983 02:52:23.860 --> 02:52:26.400 to the last sentence begins quote: 2984 02:52:26.400 --> 02:52:29.970 "PG&E has not demonstrated that there is a market 2985 02:52:29.970 --> 02:52:32.170 "for additional securitized debt 2986 02:52:32.170 --> 02:52:33.880 "covering the earlier period." 2987 02:52:33.880 --> 02:52:35.280 Close quote. 2988 02:52:35.280 --> 02:52:36.113 Do you see that? 2989 02:52:36.113 --> 02:52:36.946 Yes. 2990 02:52:36.946 --> 02:52:37.779 Can you explain what that means? 2991 02:52:41.100 --> 02:52:42.910 Personally I have a concern 2992 02:52:42.910 --> 02:52:45.710 that you may saturate the market. 2993 02:52:45.710 --> 02:52:49.790 We're talking about really large sums of money, you know, 2994 02:52:49.790 --> 02:52:52.680 seven billion here, six billion there. 2995 02:52:52.680 --> 02:52:56.400 I mean in previous, if one goes back 2996 02:52:56.400 --> 02:52:59.060 and looks at previous securitizations, 2997 02:53:00.400 --> 02:53:02.260 10 billion was a lot of money. 2998 02:53:03.900 --> 02:53:08.900 And we're now dealing with the wildfire fund securitization 2999 02:53:10.330 --> 02:53:14.270 adopted by 1054, which is 11 billion 3000 02:53:15.294 --> 02:53:18.420 and we're looking at PG&E potentially coming in 3001 02:53:18.420 --> 02:53:21.460 with its proposed seven billion. 3002 02:53:21.460 --> 02:53:23.930 I mean it's just a question of whether the market 3003 02:53:23.930 --> 02:53:27.240 gets saturated, whether there's interest in that. 3004 02:53:27.240 --> 02:53:29.390 It's an empirical question. 3005 02:53:29.390 --> 02:53:31.914 You would expect experienced investment bankers 3006 02:53:31.914 --> 02:53:35.760 to have a good visibility on that? 3007 02:53:37.150 --> 02:53:40.490 Presumably they would, the market would signal 3008 02:53:40.490 --> 02:53:41.640 whether there was interest. 3009 02:53:41.640 --> 02:53:44.060 But from the Commission's perspective, 3010 02:53:44.060 --> 02:53:47.180 it's an issue that they should keep in mind. 3011 02:53:47.180 --> 02:53:50.151 There's not endless market 3012 02:53:50.151 --> 02:53:53.520 for different kinds of debt instruments. 3013 02:53:53.520 --> 02:53:56.570 There's consequences to having too much of, 3014 02:53:56.570 --> 02:53:58.790 if you will, too much of what PG&E 3015 02:53:58.790 --> 02:54:00.550 is considering to be a good thing. 3016 02:54:02.790 --> 02:54:07.600 On page 23 of your testimony where we are were, 3017 02:54:07.600 --> 02:54:10.270 if you go to line 10, it states, quote: 3018 02:54:14.730 --> 02:54:17.790 "Thus, the Commission should deny PG&E's proposal 3019 02:54:17.790 --> 02:54:21.560 "to securitize the seven billion dollars in debt costs 3020 02:54:21.560 --> 02:54:24.540 "and direct PG&E to use the NOLs 3021 02:54:24.540 --> 02:54:26.630 "to support the most appropriate form 3022 02:54:26.630 --> 02:54:29.810 "of unsecuritized debt that is available 3023 02:54:29.810 --> 02:54:33.690 "to PG&E to refinance the six billion dollars 3024 02:54:33.690 --> 02:54:37.600 "in short-term debt and the additional 1.35 billion 3025 02:54:37.600 --> 02:54:40.550 "due to the fire victim trust." 3026 02:54:40.550 --> 02:54:41.850 Close quote. 3027 02:54:41.850 --> 02:54:42.683 Do you see that? 3028 02:54:42.683 --> 02:54:43.683 Yes, I do. 3029 02:54:43.683 --> 02:54:45.860 And this refers back to what we were referring earlier, 3030 02:54:45.860 --> 02:54:50.000 the possibility of NOLs, shareholder asset NOLs, 3031 02:54:50.000 --> 02:54:55.000 being used to offset the dedicated rate stream 3032 02:54:55.030 --> 02:54:56.480 in the securitization, right? 3033 02:54:59.050 --> 02:55:03.810 Yes, we're referring to the NOLs, 3034 02:55:03.810 --> 02:55:06.730 or the tax savings associated with the losses. 3035 02:55:06.730 --> 02:55:10.040 So we're projecting forward that there will be a stream 3036 02:55:10.040 --> 02:55:12.940 of money that would otherwise have been paid 3037 02:55:12.940 --> 02:55:17.240 to the IRS that would be available to support the debt. 3038 02:55:17.240 --> 02:55:18.073 And-- 3039 02:55:20.030 --> 02:55:23.030 And so you would agree it would be appropriate 3040 02:55:23.030 --> 02:55:25.390 to use NOLs generated by the payment 3041 02:55:25.390 --> 02:55:29.430 of wildfire claims costs to refinance the six billion 3042 02:55:29.430 --> 02:55:32.740 in temporary utility debt, as I read this, correct? 3043 02:55:33.740 --> 02:55:36.792 Yes, to the extent, I mean PG&E asserted 3044 02:55:36.792 --> 02:55:41.792 that it had those NOLs in sufficient levels 3045 02:55:42.000 --> 02:55:45.730 to be able to cover the cost of the securitization. 3046 02:55:46.700 --> 02:55:51.700 Presumably, it's reasonably close to the cost of debt 3047 02:55:52.310 --> 02:55:55.820 that's not securitized in the same manner. 3048 02:55:55.820 --> 02:55:58.120 And I understand that you oppose securitization. 3049 02:55:58.120 --> 02:56:00.600 But, to the extent that securitization 3050 02:56:00.600 --> 02:56:02.530 were approved by the Commission, 3051 02:56:02.530 --> 02:56:05.170 you would agree that those NOLs could equally be used, 3052 02:56:05.170 --> 02:56:08.060 instead, to offset the dedicated rate component 3053 02:56:08.060 --> 02:56:10.180 on customer bills, right? 3054 02:56:10.180 --> 02:56:12.290 Yes, the math would definitely work out. 3055 02:56:14.500 --> 02:56:15.650 No further questions. 3056 02:56:16.700 --> 02:56:18.170 Thank you, Mr. Allred. 3057 02:56:18.170 --> 02:56:19.003 Mr. Alcantar? 3058 02:56:23.774 --> 02:56:25.010 Good day, Ms. Yap, good to see you. 3059 02:56:25.010 --> 02:56:25.843 Good day. 3060 02:56:27.140 --> 02:56:29.570 Just really one question. 3061 02:56:29.570 --> 02:56:32.130 I'm interested in your definition, 3062 02:56:32.130 --> 02:56:34.930 as opposed to perhaps the question the way it was phrased 3063 02:56:34.930 --> 02:56:37.800 to you, of the definition of risk of securitization. 3064 02:56:39.345 --> 02:56:40.660 Could you clarify that for us, please? 3065 02:56:41.910 --> 02:56:45.410 Is it only the event of a future PG&E bankruptcy 3066 02:56:45.410 --> 02:56:48.771 or are there other risks you had in mind in your testimony 3067 02:56:48.771 --> 02:56:53.771 on page 23 (speaking off microphone). 3068 02:56:56.300 --> 02:57:00.060 I'm, as I think I've expressed in my testimony, 3069 02:57:00.060 --> 02:57:03.490 I am concerned that the ratepayers would, 3070 02:57:03.490 --> 02:57:06.730 there are circumstances under which the ratepayers 3071 02:57:06.730 --> 02:57:09.670 could basically be left holding the bag 3072 02:57:09.670 --> 02:57:11.970 and that's what I'm focused on here. 3073 02:57:12.950 --> 02:57:17.950 And then I also think there is a real issue as to whether, 3074 02:57:19.310 --> 02:57:22.520 you know, if that were, I mean if that were to occur 3075 02:57:22.520 --> 02:57:25.380 and the ratepayers are left holding the bag, 3076 02:57:25.380 --> 02:57:29.640 would the Commission otherwise have made the determination 3077 02:57:29.640 --> 02:57:34.640 that 100% of the seven billion dollar obligation 3078 02:57:34.640 --> 02:57:39.300 was just and reasonable to place in rates. 3079 02:57:39.300 --> 02:57:43.020 And so, there's this disconnect between what the Commission 3080 02:57:43.020 --> 02:57:46.820 would have done under ordinary circumstances 3081 02:57:46.820 --> 02:57:51.820 had PG&E come in and asked to recover those monies 3082 02:57:52.070 --> 02:57:54.612 and it has a right to file an application. 3083 02:57:54.612 --> 02:57:57.830 But, the Commission would have gone through that process. 3084 02:57:57.830 --> 02:58:01.650 That's the disconnect here that I'm very concerned about. 3085 02:58:01.650 --> 02:58:04.150 Could you compare your assessment 3086 02:58:04.150 --> 02:58:06.840 of the risk of securitization 3087 02:58:06.840 --> 02:58:09.750 with what you understand PG&E's view 3088 02:58:10.790 --> 02:58:13.340 of any risk of securitization? 3089 02:58:13.340 --> 02:58:14.750 Object to the form. 3090 02:58:16.590 --> 02:58:17.560 Overruled. 3091 02:58:20.690 --> 02:58:21.670 It's a little difficult, 3092 02:58:21.670 --> 02:58:24.580 'cause I don't know exactly what their definition is. 3093 02:58:24.580 --> 02:58:29.460 But, my understanding is the Commission 3094 02:58:29.460 --> 02:58:34.306 would attach a payment, a rate, 3095 02:58:34.306 --> 02:58:38.380 that is paid off for 20 years or 15 years, 3096 02:58:38.380 --> 02:58:43.050 whatever the life of the debt is and that's dedicated. 3097 02:58:45.480 --> 02:58:50.480 It can't be undone without violating the securities, 3098 02:58:50.920 --> 02:58:52.910 the terms of, I mean all sorts 3099 02:58:52.910 --> 02:58:57.910 of agreements are signed off in doing a securitization. 3100 02:58:57.930 --> 02:59:02.120 So it's not something, you know, in five years, 3101 02:59:02.120 --> 02:59:05.860 if PG&E's bankrupt, you can't just say, oh well, 3102 02:59:05.860 --> 02:59:08.580 we really didn't mean it, the ratepayers don't have to pay. 3103 02:59:08.580 --> 02:59:11.480 The ratepayers still have to pay that rate, 3104 02:59:11.480 --> 02:59:14.090 regardless of the circumstances. 3105 02:59:14.090 --> 02:59:15.770 That's my understanding. 3106 02:59:15.770 --> 02:59:18.100 That's the basis for my concern 3107 02:59:18.100 --> 02:59:21.140 about if there were a bankruptcy 3108 02:59:21.140 --> 02:59:25.020 that basically upset the apple cart 3109 02:59:25.020 --> 02:59:26.830 with respect to the NOLs. 3110 02:59:29.491 --> 02:59:30.324 I appreciate that response. 3111 02:59:30.324 --> 02:59:33.270 The question I think I'm trying to sort out 3112 02:59:33.270 --> 02:59:38.270 is in your review and assessment of PG&E testimony 3113 02:59:39.840 --> 02:59:43.363 associated with its optimism, if you will, with respect 3114 02:59:43.363 --> 02:59:46.750 to the benefits of securitization, 3115 02:59:49.306 --> 02:59:51.730 do you see any risk at all in their assessment? 3116 02:59:52.990 --> 02:59:55.560 Objection, vague, lacks foundation. 3117 02:59:55.560 --> 02:59:56.520 Overruled. 3118 02:59:58.720 --> 03:00:01.260 You know, I don't have their testimony in front of me, 3119 03:00:01.260 --> 03:00:05.040 so I can't really speak to what they were saying. 3120 03:00:06.670 --> 03:00:08.220 Nothing further, your Honor. 3121 03:00:08.220 --> 03:00:09.500 Thank you, Mr. Alcantar. 3122 03:00:09.500 --> 03:00:10.890 Mr. Bloom? 3123 03:00:10.890 --> 03:00:12.830 Thank you, your Honor. 3124 03:00:12.830 --> 03:00:13.790 Good afternoon, Ms. Yap. 3125 03:00:13.790 --> 03:00:15.047 Good afternoon. 3126 03:00:15.047 --> 03:00:15.880 My name is Jerry Bloom. 3127 03:00:15.880 --> 03:00:17.780 I'm here on behalf of the Tort Claimants Committee. 3128 03:00:21.860 --> 03:00:25.800 On page 10 of your testimony, you address the evolution 3129 03:00:25.800 --> 03:00:30.800 of PG&E's management structure, specifically talk about 3130 03:00:31.296 --> 03:00:34.950 that prior to 2000, PG&E had organized 3131 03:00:34.950 --> 03:00:37.490 its business around geographic regions. 3132 03:00:37.490 --> 03:00:38.580 Is that correct? 3133 03:00:38.580 --> 03:00:39.730 Yes, that is correct. 3134 03:00:40.630 --> 03:00:43.890 And then we had the PG&E bankruptcy in 2001. 3135 03:00:43.890 --> 03:00:48.890 But in the mid-2000s, you state in your testimony at page 11 3136 03:00:49.370 --> 03:00:53.270 that PG&E moved to a centralized organizational structure. 3137 03:00:53.270 --> 03:00:54.620 Is that correct? 3138 03:00:54.620 --> 03:00:56.210 Yes. 3139 03:00:56.210 --> 03:00:59.070 And now, in the questions you've already been asked 3140 03:01:00.332 --> 03:01:02.790 this afternoon by PG&E's counsel, 3141 03:01:02.790 --> 03:01:07.790 we find that PG&E has teed up a regional structuring plan 3142 03:01:10.280 --> 03:01:13.590 that it plans to submit in the future. 3143 03:01:13.590 --> 03:01:15.040 We just have a little bit of detail now, 3144 03:01:15.040 --> 03:01:17.470 but this is a plan that's forthcoming? 3145 03:01:17.470 --> 03:01:20.987 Yes, there was a half a page, I believe, 3146 03:01:20.987 --> 03:01:22.600 in their testimony. 3147 03:01:22.600 --> 03:01:23.433 That's correct. 3148 03:01:23.433 --> 03:01:26.210 And is your testimony, for clarification today, 3149 03:01:26.210 --> 03:01:28.840 that you would like to see that filed or a requirement 3150 03:01:28.840 --> 03:01:32.060 that that get filed in the General Rate Case, 3151 03:01:32.060 --> 03:01:33.110 in their next General Rate Case, 3152 03:01:33.110 --> 03:01:34.660 which would be the 2021 filing? 3153 03:01:37.360 --> 03:01:42.360 My proposal is that it, you would address 3154 03:01:45.400 --> 03:01:49.200 the Plan of Reorganization in the context 3155 03:01:49.200 --> 03:01:50.900 of the General Rate Case, 3156 03:01:52.090 --> 03:01:56.100 that PG&E would, well, let me back up. 3157 03:01:56.100 --> 03:01:59.830 That PG&E would take the year that it would have 3158 03:01:59.830 --> 03:02:04.370 between the time the Commission addressed the POR 3159 03:02:04.370 --> 03:02:07.890 and the time it filed its General Rate Case 3160 03:02:07.890 --> 03:02:12.621 for test year 2023, that that would be filed 3161 03:02:12.621 --> 03:02:17.621 in the fall of 2021 and PG&E would incorporate 3162 03:02:19.150 --> 03:02:24.150 in that filing the new organization, basically. 3163 03:02:25.120 --> 03:02:29.093 And I suspect that there may be some considerable 3164 03:02:30.330 --> 03:02:35.330 differences in the way they describe their organization, 3165 03:02:37.570 --> 03:02:41.380 it could be reflected in O&M costs, et cetera. 3166 03:02:41.380 --> 03:02:43.800 But whatever, it gets incorporated 3167 03:02:43.800 --> 03:02:45.860 in that General Rate Case filing. 3168 03:02:45.860 --> 03:02:48.540 That's what my vision was. 3169 03:02:48.540 --> 03:02:50.030 And in the questions you were asked 3170 03:02:50.030 --> 03:02:53.625 earlier this afternoon, do you have an idea 3171 03:02:53.625 --> 03:02:57.570 of the timing it will take that whole process, 3172 03:02:57.570 --> 03:03:00.390 if you will, you talk about the complications 3173 03:03:00.390 --> 03:03:02.490 and the pervasiveness of that change so 3174 03:03:02.490 --> 03:03:05.190 to actually go through those proposals in the GRC, 3175 03:03:05.190 --> 03:03:07.770 begin implementing, do you have any idea 3176 03:03:07.770 --> 03:03:08.603 what we're talking about, 3177 03:03:08.603 --> 03:03:10.521 what we're looking at for the time 3178 03:03:10.521 --> 03:03:11.780 to implement those changes? 3179 03:03:11.780 --> 03:03:14.700 Well, to do a major reorganization, 3180 03:03:14.700 --> 03:03:17.540 it's not something you can do in four months. 3181 03:03:17.540 --> 03:03:19.770 You can talk about it in four months. 3182 03:03:19.770 --> 03:03:21.200 You might have a better idea 3183 03:03:21.200 --> 03:03:23.280 than you have today in four months. 3184 03:03:24.230 --> 03:03:28.020 But, I think it takes years 3185 03:03:28.020 --> 03:03:32.290 to actually effect a reorganization. 3186 03:03:33.660 --> 03:03:36.480 Okay, and if you've been around 3187 03:03:36.480 --> 03:03:39.590 or listened to cross-examination by Mr. Abrams in this 3188 03:03:39.590 --> 03:03:42.850 and also from the victims' perspective who's worried 3189 03:03:42.850 --> 03:03:46.040 about what's gonna happen in the interim period, 3190 03:03:46.040 --> 03:03:48.440 there are questions of how the system operates 3191 03:03:48.440 --> 03:03:51.910 and what we do as we effectuate these longer-term changes 3192 03:03:51.910 --> 03:03:53.670 that are coming up, is that correct? 3193 03:03:54.620 --> 03:03:58.310 I have, I can appreciate 3194 03:03:58.310 --> 03:04:02.600 that Mr. Abrams has some concerns about the victims. 3195 03:04:02.600 --> 03:04:04.700 It's certainly reflected in his questions. 3196 03:04:05.650 --> 03:04:09.280 Okay, so if I understand your testimony, on page 11, 3197 03:04:10.190 --> 03:04:13.510 you discuss the matrix type organization 3198 03:04:13.510 --> 03:04:17.340 and you say that the implementation 3199 03:04:17.340 --> 03:04:21.150 of this would allow the Commission or PG&E 3200 03:04:22.013 --> 03:04:22.890 to start acting more quickly 3201 03:04:22.890 --> 03:04:24.630 in what you call an interim period. 3202 03:04:24.630 --> 03:04:28.720 So could you explain how that recommendation works 3203 03:04:28.720 --> 03:04:32.540 or what happens in the interim period and the necessity 3204 03:04:32.540 --> 03:04:35.540 of why you want something implemented in the interim period? 3205 03:04:39.330 --> 03:04:43.553 My, I mean, again, my vision was that the fully 3206 03:04:45.620 --> 03:04:48.600 fleshed out plan would be reflected 3207 03:04:48.600 --> 03:04:50.650 in the General Rate Case in about a year. 3208 03:04:51.982 --> 03:04:56.982 So in the meantime, there are steps that PG&E could take 3209 03:04:58.660 --> 03:05:02.200 to address the types of concerns 3210 03:05:02.200 --> 03:05:05.200 that have emerged and I describe it. 3211 03:05:05.200 --> 03:05:08.790 I think I described the creation 3212 03:05:08.790 --> 03:05:13.620 of the troubleshooter type person who would try 3213 03:05:13.620 --> 03:05:18.620 to integrate, I mean it is a matrix or a pseudo matrix type 3214 03:05:20.220 --> 03:05:25.220 of organization structure where you have two lines 3215 03:05:27.500 --> 03:05:29.860 of responsibility for an individual, 3216 03:05:29.860 --> 03:05:32.270 they have two lines of reporting. 3217 03:05:32.270 --> 03:05:36.370 So generally people, well, not always, but, 3218 03:05:36.370 --> 03:05:38.420 if you don't have a matrix organization, 3219 03:05:38.420 --> 03:05:40.170 you have a single line of reporting 3220 03:05:41.023 --> 03:05:44.640 and generally organized around some, you know, 3221 03:05:44.640 --> 03:05:46.760 you could be organized around geography, 3222 03:05:46.760 --> 03:05:49.110 but a lot of times, it's functional. 3223 03:05:49.110 --> 03:05:53.230 And PG&E's is what I'm calling task-oriented, 3224 03:05:53.230 --> 03:05:58.230 'cause it's functional with a twist, lots and lots 3225 03:05:58.400 --> 03:06:02.500 and lots of functions broken out into lots of detail. 3226 03:06:04.380 --> 03:06:07.280 So you create a situation where you begin 3227 03:06:07.280 --> 03:06:12.280 to draw the attention of people 3228 03:06:12.380 --> 03:06:15.250 who are focused on the function. 3229 03:06:15.250 --> 03:06:19.000 They're focused on the, I'm gonna go out and, you know, 3230 03:06:19.000 --> 03:06:22.480 I'm gonna plan something or I'm going to engineer something 3231 03:06:22.480 --> 03:06:25.790 or I'm gonna go repair something and I'm thinking of it 3232 03:06:25.790 --> 03:06:30.790 in terms of my limited focus and I'm, what we're trying 3233 03:06:31.890 --> 03:06:36.140 to do is broaden that focus so that the folks, 3234 03:06:36.140 --> 03:06:39.470 that they're thinking, as I believe I say in my testimony, 3235 03:06:39.470 --> 03:06:44.470 more holistically, so that for each geographic region, 3236 03:06:44.510 --> 03:06:47.670 you begin to get better communication 3237 03:06:47.670 --> 03:06:51.590 among the different task area 3238 03:06:51.590 --> 03:06:56.430 or task motivated people within a particular geography. 3239 03:06:56.430 --> 03:06:58.040 Now, they're still reporting back 3240 03:06:58.040 --> 03:07:01.790 to San Francisco or to the sub-regions. 3241 03:07:01.790 --> 03:07:03.730 So they still have that responsibility 3242 03:07:05.555 --> 03:07:06.860 in terms of quality control, 3243 03:07:06.860 --> 03:07:08.730 in terms of what they're supposed to be doing, 3244 03:07:08.730 --> 03:07:11.690 how fast they're doing it, but they begin 3245 03:07:11.690 --> 03:07:16.690 to have responsibilities for, let's compare notes. 3246 03:07:16.790 --> 03:07:20.050 And this troubleshooter, I was trying to think of something 3247 03:07:20.050 --> 03:07:22.660 that would provide an opportunity where you 3248 03:07:22.660 --> 03:07:25.430 have somebody who actually has responsibility 3249 03:07:25.430 --> 03:07:30.430 to weave together, across all the different tasks. 3250 03:07:30.960 --> 03:07:32.500 They're important tasks, right? 3251 03:07:32.500 --> 03:07:36.600 But, they're individually done and they'll be done 3252 03:07:36.600 --> 03:07:38.730 in different geography, you know, 3253 03:07:38.730 --> 03:07:41.830 different geographical areas at different times 3254 03:07:41.830 --> 03:07:46.093 and they're not thinking, oh, for the Lake County 3255 03:07:48.050 --> 03:07:51.690 which came up earlier, they're not thinking: 3256 03:07:51.690 --> 03:07:54.440 Oh, what's the best for Lake, 3257 03:07:54.440 --> 03:07:58.330 or are we covering all the bases in Lake County? 3258 03:07:58.330 --> 03:08:02.340 So the troubleshooter would start that up, 3259 03:08:02.340 --> 03:08:04.760 because it's gonna be their responsibility 3260 03:08:04.760 --> 03:08:08.300 to make sure that, from Lake County's perspective, 3261 03:08:08.300 --> 03:08:10.530 they're getting stuff covered. 3262 03:08:10.530 --> 03:08:13.670 And if they aren't, that troubleshooter knows who to go 3263 03:08:13.670 --> 03:08:18.670 to back in the various line positions to try to get 3264 03:08:19.610 --> 03:08:22.950 that effected and figure out, well, what's causing, 3265 03:08:22.950 --> 03:08:25.030 you know, why are things falling through the cracks 3266 03:08:25.030 --> 03:08:27.220 or why isn't something being covered. 3267 03:08:27.220 --> 03:08:29.930 Now, obviously, they're gonna be competing 3268 03:08:29.930 --> 03:08:33.150 with other demands on these resources. 3269 03:08:33.150 --> 03:08:35.350 So it's not a perfect, you know, 3270 03:08:35.350 --> 03:08:38.670 Lake County won't just get everything it wants, 3271 03:08:38.670 --> 03:08:41.520 but Lake County gets, if you will, 3272 03:08:41.520 --> 03:08:46.520 represented in the organization kind of geographically 3273 03:08:46.660 --> 03:08:49.430 before we get to the reorganization, 3274 03:08:49.430 --> 03:08:52.890 which is a year or two years or maybe even three years off. 3275 03:08:54.158 --> 03:08:55.800 So that was the idea. 3276 03:08:55.800 --> 03:08:59.750 You anticipated very well where my questions were going. 3277 03:08:59.750 --> 03:09:02.470 On page 14 of your testimony, in fact, 3278 03:09:02.470 --> 03:09:06.684 you discuss the horizontal linkage and proposals 3279 03:09:06.684 --> 03:09:11.684 and in that context you specifically, as you just referred, 3280 03:09:12.240 --> 03:09:15.920 discuss preventing things falling through the cracks 3281 03:09:15.920 --> 03:09:17.980 and troubleshooting in terms of that proposal. 3282 03:09:17.980 --> 03:09:19.130 Is that correct? 3283 03:09:19.130 --> 03:09:19.963 Yes. 3284 03:09:19.963 --> 03:09:20.796 And that's part of the (mumbles) 3285 03:09:20.796 --> 03:09:23.430 and is this horizontal linkage, 'cause I wasn't clear, 3286 03:09:23.430 --> 03:09:26.380 is that also an interim step or is that something 3287 03:09:26.380 --> 03:09:30.200 that's more generic or more structural? 3288 03:09:30.200 --> 03:09:35.200 It's an interim step and it could be set aside. 3289 03:09:35.460 --> 03:09:37.600 I mean the people that'll be thinking 3290 03:09:37.600 --> 03:09:40.941 about the reorganization, you know, they can think about 3291 03:09:40.941 --> 03:09:45.941 to the extent that leaving matrix kind of, you know, 3292 03:09:48.760 --> 03:09:50.780 within the organization, you could decide you wanna 3293 03:09:50.780 --> 03:09:53.180 have a mini matrix within it. 3294 03:09:53.180 --> 03:09:57.520 I think Ms. Powell might have referred, someone referred 3295 03:09:57.520 --> 03:10:01.120 to a matrix style organization, no, anyway, 3296 03:10:01.120 --> 03:10:04.330 one of the witnesses I heard referred 3297 03:10:04.330 --> 03:10:06.560 to a matrix or type organization. 3298 03:10:06.560 --> 03:10:09.650 I think it was in a customer service context. 3299 03:10:09.650 --> 03:10:13.440 So I mean you can have little matrix organizations. 3300 03:10:13.440 --> 03:10:15.330 So they could decide to preserve it 3301 03:10:15.330 --> 03:10:18.310 or they could decide to set it aside. 3302 03:10:18.310 --> 03:10:20.390 You would agree, then, and if I understand 3303 03:10:20.390 --> 03:10:23.090 the point you made earlier, it's really important 3304 03:10:23.090 --> 03:10:26.720 as we implement the Plan of Reorganization 3305 03:10:26.720 --> 03:10:29.740 and move forward and a lot of the details get filled in, 3306 03:10:29.740 --> 03:10:33.510 the Restructuring Plan, things come to the Commission, 3307 03:10:33.510 --> 03:10:37.370 to have a system in place that allows us to troubleshoot 3308 03:10:37.370 --> 03:10:40.060 or identify, as you said a minute ago, 3309 03:10:40.060 --> 03:10:43.770 as specific concerns or problems or issues arise, 3310 03:10:43.770 --> 03:10:46.220 a system in place to identify those things 3311 03:10:46.220 --> 03:10:48.230 to take care of them, not wait till two or three 3312 03:10:48.230 --> 03:10:51.340 or four years from now and in the meanwhile, 3313 03:10:51.340 --> 03:10:53.280 things fell through cracks or, God forbid, 3314 03:10:53.280 --> 03:10:57.010 we end up with another catastrophic event or things 3315 03:10:57.010 --> 03:11:02.010 that we don't want to be happening in the meantime? 3316 03:11:02.090 --> 03:11:05.050 These are meant to be things that 3317 03:11:05.050 --> 03:11:10.050 you would effect them very quickly and you could adapt them 3318 03:11:11.070 --> 03:11:16.070 to how things evolve as people's thinking 3319 03:11:16.780 --> 03:11:20.160 about what regionalization means 3320 03:11:20.160 --> 03:11:22.360 from an organizational perspective. 3321 03:11:23.560 --> 03:11:26.730 These interim steps are adaptable, 3322 03:11:26.730 --> 03:11:30.240 and you could fashion measures to try 3323 03:11:30.240 --> 03:11:32.190 to figure out if they're helpful or not 3324 03:11:33.067 --> 03:11:37.120 and you could adapt them to make them better, you know, 3325 03:11:37.120 --> 03:11:39.670 better, I mean maybe the troubleshooter 3326 03:11:39.670 --> 03:11:42.050 isn't the perfect solution. 3327 03:11:42.050 --> 03:11:44.718 You could come up with something that's even better, 3328 03:11:44.718 --> 03:11:48.840 but the point here is that you do have the options 3329 03:11:48.840 --> 03:11:51.390 to take immediate steps. 3330 03:11:51.390 --> 03:11:53.541 And I was struggling with the same thing too, 3331 03:11:53.541 --> 03:11:54.851 like call them. 3332 03:11:54.851 --> 03:11:55.684 What you're saying is we need to fashion, 3333 03:11:55.684 --> 03:11:57.680 whether they're measures or metrics 3334 03:11:57.680 --> 03:12:01.650 or some type of identifiable metrics 3335 03:12:01.650 --> 03:12:03.740 or things that would bring those issues 3336 03:12:03.740 --> 03:12:06.266 that you talked about, those concerns that surface 3337 03:12:06.266 --> 03:12:09.000 to the surface and get them taken along the way, 3338 03:12:09.000 --> 03:12:11.320 so we don't end up down the line saying, 3339 03:12:11.320 --> 03:12:13.160 how did we get here with a catastrophic event? 3340 03:12:13.160 --> 03:12:15.790 We can back that up, and take care 3341 03:12:15.790 --> 03:12:17.530 of those things as we effectuate change. 3342 03:12:17.530 --> 03:12:21.780 Or even if we have a restructuring plan in place, 3343 03:12:21.780 --> 03:12:23.560 as we're implementing it, if we get off track, 3344 03:12:23.560 --> 03:12:27.670 we can make adjustments along the way. 3345 03:12:27.670 --> 03:12:30.780 I would agree that it's definitely, 3346 03:12:30.780 --> 03:12:33.410 you could definitely make adjustments to this. 3347 03:12:33.410 --> 03:12:38.410 I mean and it would work within what PG&E's proposing 3348 03:12:39.220 --> 03:12:44.220 as the overarching, you know, regionalization plan. 3349 03:12:45.440 --> 03:12:50.440 This is an interim step that could be carried forward 3350 03:12:51.000 --> 03:12:53.570 or set aside, as appropriate. 3351 03:12:54.787 --> 03:12:55.760 Okay, so taking out what you said, 3352 03:12:55.760 --> 03:12:58.660 this is all within what PG&E is proposing, 3353 03:12:58.660 --> 03:13:00.143 is what you just said, correct? 3354 03:13:00.143 --> 03:13:02.760 Yes, it wouldn't slow it down. 3355 03:13:02.760 --> 03:13:04.190 It shouldn't slow it down. 3356 03:13:04.190 --> 03:13:09.110 It should, it should help. 3357 03:13:10.050 --> 03:13:13.280 And in fact, thinking about the work 3358 03:13:16.150 --> 03:13:18.220 that troubleshooters would do, I think, 3359 03:13:18.220 --> 03:13:21.030 would actually be inspirational, or should be, 3360 03:13:21.030 --> 03:13:24.900 in terms of thinking about what the real needs are, 3361 03:13:24.900 --> 03:13:26.880 in terms of regionalizing the company, 3362 03:13:27.748 --> 03:13:29.230 what are you really trying to accomplish. 3363 03:13:29.230 --> 03:13:31.840 And would you accept that inspiration 3364 03:13:31.840 --> 03:13:35.510 that you're talking about by being able to troubleshoot 3365 03:13:35.510 --> 03:13:38.610 and make course corrections, I think will be a nice way 3366 03:13:38.610 --> 03:13:42.170 to frame this, would certainly help victims 3367 03:13:42.170 --> 03:13:44.410 who need a peace of mind that what we're doing 3368 03:13:44.410 --> 03:13:45.920 is leading to a different result 3369 03:13:45.920 --> 03:13:47.640 or we can make corrections along the way 3370 03:13:47.640 --> 03:13:50.710 to optimize our ability to get to a better, 3371 03:13:50.710 --> 03:13:52.360 safer and more affordable system? 3372 03:13:53.740 --> 03:13:57.650 I would think that the victims 3373 03:13:57.650 --> 03:14:01.600 and the communities from which those victims 3374 03:14:01.600 --> 03:14:06.600 came would be reassured by the creation of a troubleshooter. 3375 03:14:09.510 --> 03:14:11.150 And we're gonna call it troubleshooter, 3376 03:14:11.150 --> 03:14:14.910 'cause that's what I chose, but, that type of position, 3377 03:14:14.910 --> 03:14:18.000 I think that would be enormously reassuring 3378 03:14:18.000 --> 03:14:22.880 to them because it would be demonstration 3379 03:14:22.880 --> 03:14:27.880 that the organization is taking the community perspective 3380 03:14:28.290 --> 03:14:33.290 very seriously, not just from a hold your hand 3381 03:14:33.290 --> 03:14:36.190 at the customer end of things, 3382 03:14:36.190 --> 03:14:40.850 but from across the fabric of of the corporation, 3383 03:14:42.010 --> 03:14:44.600 across the engineering, across the maintenance, 3384 03:14:44.600 --> 03:14:47.710 the personnel, that people would be, 3385 03:14:49.300 --> 03:14:54.300 there would be an attempt to fold in that tech-- 3386 03:14:57.060 --> 03:14:58.190 I think you've answered the question already. 3387 03:14:58.190 --> 03:14:59.411 Okay. 3388 03:14:59.411 --> 03:15:00.940 I think she has too. 3389 03:15:00.940 --> 03:15:01.810 Thank you, Your Honor. 3390 03:15:01.810 --> 03:15:03.730 That concludes my cross. 3391 03:15:03.730 --> 03:15:05.218 Thank you, Ms. Yap. 3392 03:15:05.218 --> 03:15:07.620 Ms. Sheriff, do you have any redirect? 3393 03:15:07.620 --> 03:15:11.060 I have one question for Ms. Yap on redirect. 3394 03:15:11.060 --> 03:15:13.451 Okay, she's done most 3395 03:15:13.451 --> 03:15:14.292 of the redirect already herself. 3396 03:15:14.292 --> 03:15:15.640 (laughing) 3397 03:15:15.640 --> 03:15:18.720 Yes, I'm blessed with my witnesses, Your Honor. 3398 03:15:18.720 --> 03:15:20.350 Thank you. 3399 03:15:20.350 --> 03:15:24.390 Ms. Yap, on what's been marked for identification 3400 03:15:24.390 --> 03:15:28.690 as PG&E-X-2, which is the CLECA Response Number Six, 3401 03:15:31.340 --> 03:15:36.340 counsel for PG&E asked you about specifically the risk 3402 03:15:36.560 --> 03:15:40.150 of securitization from another PG&E bankruptcy. 3403 03:15:40.150 --> 03:15:44.170 You responded to that and also talked 3404 03:15:44.170 --> 03:15:47.140 about the concern over market saturation. 3405 03:15:47.140 --> 03:15:49.080 What other risks do you see 3406 03:15:49.080 --> 03:15:51.150 to the ratepayers of securitization? 3407 03:16:10.763 --> 03:16:11.840 I thought Mr. Alcantar asked that question. 3408 03:16:11.840 --> 03:16:13.880 Yeah, I'm sorry. 3409 03:16:13.880 --> 03:16:18.880 I see it as being the ratepayers are forever bound 3410 03:16:19.860 --> 03:16:23.380 to paying that, you know, paying that amount of money, 3411 03:16:23.380 --> 03:16:27.660 regardless of what happens downstream 3412 03:16:27.660 --> 03:16:29.720 to PG&E's ability to offset it. 3413 03:16:30.703 --> 03:16:32.390 I think that's really the major risk. 3414 03:16:33.725 --> 03:16:34.860 Okay, thank you. 3415 03:16:34.860 --> 03:16:36.800 Thank you, Ms. Sheriff. 3416 03:16:36.800 --> 03:16:38.640 Let's go off the record for a second. 3417 03:16:43.300 --> 03:16:45.500 Did you, identify (speaking off microphone). 3418 03:16:53.830 --> 03:16:55.670 I did not go over what was in 1E. 3419 03:16:55.670 --> 03:16:59.329 Would you like for me to have her go over what was in 1E? 3420 03:16:59.329 --> 03:17:00.672 (speaking off microphone) what it is. 3421 03:17:00.672 --> 03:17:03.100 Actually, (speaking off microphone) CLECA 1E 3422 03:17:04.727 --> 03:17:05.560 which is an errata to CLECA1. 3423 03:17:07.579 --> 03:17:08.847 Yes Your Honor. 3424 03:17:08.847 --> 03:17:09.680 Okay are there any objections to that? 3425 03:17:12.031 --> 03:17:14.750 Okay, let's not bother (speaking off microphone) CLECA 1E 3426 03:17:19.345 --> 03:17:20.540 unless there's objection 3427 03:17:20.540 --> 03:17:22.171 to that we'll wait at CLECA2 3428 03:17:22.171 --> 03:17:23.160 since it's not (speaking off microphone). 3429 03:17:23.160 --> 03:17:25.021 Yes, thank you. 3430 03:17:25.021 --> 03:17:26.520 Okay. 3431 03:17:28.460 --> 03:17:29.293 On the record. 3432 03:17:31.450 --> 03:17:32.440 I'm assuming there's no more 3433 03:17:32.440 --> 03:17:35.310 cross-examination for this witness. 3434 03:17:35.310 --> 03:17:36.670 Seeing none. 3435 03:17:36.670 --> 03:17:39.530 Ms. Sheriff, do you wish to move some exhibits? 3436 03:17:39.530 --> 03:17:40.363 Yes, your Honor. 3437 03:17:40.363 --> 03:17:41.940 May I please ask to have moved 3438 03:17:41.940 --> 03:17:46.940 into the record Exhibit CLECA-1 and Exhibit CLECA-1-E? 3439 03:17:48.230 --> 03:17:49.200 Is there any objection 3440 03:17:49.200 --> 03:17:51.270 to the receipt of those two exhibits? 3441 03:17:51.270 --> 03:17:52.870 Provided that I understand correctly 3442 03:17:52.870 --> 03:17:57.460 that 1-E completely replaces pages seven and eight of one, 3443 03:17:57.460 --> 03:17:59.180 I have no objection. 3444 03:17:59.180 --> 03:18:02.480 CLECA-1-E has a red line 3445 03:18:02.480 --> 03:18:04.620 that shows exactly what is changed. 3446 03:18:04.620 --> 03:18:05.500 Oh, okay. 3447 03:18:05.500 --> 03:18:07.450 And so it's pretty clear 3448 03:18:07.450 --> 03:18:11.270 what it does on pages seven and eight of CLECA-1. 3449 03:18:13.500 --> 03:18:17.700 Hearing no objection, CLECA-1 and CLECA-1-E are admitted. 3450 03:18:19.300 --> 03:18:22.860 Thank you, Ms. Yap, you may step down. 3451 03:18:22.860 --> 03:18:24.350 Off the record. 3452 03:18:24.350 --> 03:18:27.200 Let's get Kenney up here so that Ms. Sheriff can do that. 3453 03:18:37.769 --> 03:18:38.622 I can't reach. 3454 03:18:38.622 --> 03:18:41.289 (faint chatter) 3455 03:19:30.580 --> 03:19:31.680 On the record. 3456 03:19:32.740 --> 03:19:34.470 P&E, call your witness, please. 3457 03:19:35.860 --> 03:19:36.693 Thank you, Your Honor. 3458 03:19:36.693 --> 03:19:38.190 Mr. Robert Kenney. 3459 03:19:38.190 --> 03:19:39.050 Thank you. 3460 03:19:40.241 --> 03:19:41.730 Do you swear to tell the truth, the whole truth 3461 03:19:41.730 --> 03:19:42.970 and nothing but the truth? 3462 03:19:42.970 --> 03:19:43.803 I do. 3463 03:19:43.803 --> 03:19:45.110 Thank you, please be seated, 3464 03:19:45.110 --> 03:19:45.943 state your full name 3465 03:19:45.943 --> 03:19:48.510 and spell your last name for the record. 3466 03:19:48.510 --> 03:19:51.590 Full name is Robert, middle initial S, last name Kenney, 3467 03:19:51.590 --> 03:19:53.010 K-E-N-N E-Y. 3468 03:19:54.760 --> 03:19:56.030 Thank you. 3469 03:19:56.030 --> 03:19:57.426 Good afternoon, Mr. Kenney. 3470 03:19:57.426 --> 03:19:58.990 Can you state your position with PG&E? 3471 03:20:00.870 --> 03:20:03.680 Vice president, State and Regulatory Affairs. 3472 03:20:03.680 --> 03:20:07.650 Thank you and are you sponsoring PG&E Exhibit-1, 3473 03:20:07.650 --> 03:20:10.390 Chapters 10, 11 and 12? 3474 03:20:10.390 --> 03:20:11.759 Yes, I am. 3475 03:20:11.759 --> 03:20:13.390 Do you have any corrections to your testimony? 3476 03:20:13.390 --> 03:20:14.740 Two small ones, if I may. 3477 03:20:16.470 --> 03:20:19.720 Chapter 12, page four, line eight, 3478 03:20:21.410 --> 03:20:24.910 I used the word reaffirmance. 3479 03:20:24.910 --> 03:20:26.680 That should read reaffirmation. 3480 03:20:28.940 --> 03:20:33.940 Chapter 12, page five, line 20, the same correction, 3481 03:20:33.970 --> 03:20:37.070 replace the word reaffirmance with reaffirmation. 3482 03:20:38.240 --> 03:20:39.073 Thank you. 3483 03:20:39.073 --> 03:20:41.410 With those corrections, was that testimony 3484 03:20:41.410 --> 03:20:43.140 prepared by you or under your direction? 3485 03:20:43.140 --> 03:20:44.080 Yes, yes it was. 3486 03:20:44.080 --> 03:20:45.340 And with the corrections noted, 3487 03:20:45.340 --> 03:20:47.380 is it true and correct, to the best of your knowledge? 3488 03:20:47.380 --> 03:20:48.213 Yes, it is. 3489 03:20:48.213 --> 03:20:49.570 Thank you. 3490 03:20:49.570 --> 03:20:51.100 The witness is available for cross-examination. 3491 03:20:51.100 --> 03:20:52.450 Thank you, Mr. Manheim. 3492 03:20:52.450 --> 03:20:54.410 Today, the only cross of this witness 3493 03:20:54.410 --> 03:20:55.700 will be by Ms. Sheriff. 3494 03:20:55.700 --> 03:20:57.490 Go ahead, Ms. Sheriff. 3495 03:20:57.490 --> 03:20:58.323 Thank you. 3496 03:20:58.323 --> 03:21:00.590 Good afternoon, Mr. Kenney, Nora Sheriff for CLECA. 3497 03:21:00.590 --> 03:21:02.010 It's nice to see you again. 3498 03:21:02.010 --> 03:21:03.630 Likewise; good afternoon. 3499 03:21:03.630 --> 03:21:08.630 At page 10-2, lines six to seven, you reference, quote: 3500 03:21:09.700 --> 03:21:13.220 "A substantial reduction in the cost of debt." 3501 03:21:13.220 --> 03:21:14.370 End quote. 3502 03:21:14.370 --> 03:21:17.970 As the cause for the projected reduction in customer rates. 3503 03:21:20.650 --> 03:21:22.010 Let me know when you get there. 3504 03:21:25.770 --> 03:21:26.603 Yes. 3505 03:21:27.610 --> 03:21:30.620 Are you referring to anything besides the reduction 3506 03:21:30.620 --> 03:21:34.476 in the revenue requirement of about 70.7 million dollars 3507 03:21:34.476 --> 03:21:37.750 per year from lower interest rates? 3508 03:21:39.390 --> 03:21:44.320 So what's referenced there on page two, line 10, 3509 03:21:45.300 --> 03:21:47.700 as discussed in Mr. Wells' testimony, 3510 03:21:47.700 --> 03:21:50.821 is the savings that would be realized as a result 3511 03:21:50.821 --> 03:21:55.821 of debt that we would refinance at a lower rate. 3512 03:21:58.260 --> 03:21:59.600 And that is it, correct? 3513 03:21:59.600 --> 03:22:00.450 That's correct. 3514 03:22:02.400 --> 03:22:05.250 Okay, at page 10-3, you talk about the cost 3515 03:22:05.250 --> 03:22:07.630 to improve the safety of its system 3516 03:22:07.630 --> 03:22:10.570 that would have incurred, been incurred regardless 3517 03:22:10.570 --> 03:22:12.230 of the Plan of Reorganization. 3518 03:22:13.390 --> 03:22:16.130 Does that include your Wildfire Mitigation Plan 3519 03:22:16.130 --> 03:22:18.960 for 2020, 2021 and 2022? 3520 03:22:21.610 --> 03:22:22.770 You're referring to, sorry? 3521 03:22:29.200 --> 03:22:32.700 Lines nine to 10, changes in rates that result from costs 3522 03:22:32.700 --> 03:22:35.380 that PG&E would have had to incur 3523 03:22:35.380 --> 03:22:37.320 to improve the safety of its system. 3524 03:22:39.900 --> 03:22:41.660 That would be the type of costs 3525 03:22:41.660 --> 03:22:44.430 that is referenced there on lines 10 and nine and 10. 3526 03:22:44.430 --> 03:22:48.260 So costs associated with our Wildfire Mitigation Plan 3527 03:22:48.260 --> 03:22:51.860 are not costs attributable to the Plan of Reorganization 3528 03:22:51.860 --> 03:22:55.950 and are therefore, not subject to the 3292 neutral, 3529 03:22:55.950 --> 03:22:57.770 on average, analysis. 3530 03:22:57.770 --> 03:23:01.500 And does PG&E's three-year Wildfire Mitigation Plan 3531 03:23:01.500 --> 03:23:03.990 propose about 2.6 billion dollars per year 3532 03:23:03.990 --> 03:23:05.040 to harden the system? 3533 03:23:06.020 --> 03:23:07.760 That sounds directionally correct. 3534 03:23:07.760 --> 03:23:12.760 Okay, at page 10-4, line eight, you reference a quote, 3535 03:23:12.770 --> 03:23:14.860 "baseline of what would have been required 3536 03:23:14.860 --> 03:23:16.730 "absent Chapter 11." 3537 03:23:16.730 --> 03:23:18.800 I think we just discussed that that baseline 3538 03:23:18.800 --> 03:23:21.470 would include your Wildfire Mitigation Plan, correct? 3539 03:23:25.380 --> 03:23:26.880 Yes, the baseline of what would 3540 03:23:26.880 --> 03:23:29.470 have been required irrespective of the Chapter 11. 3541 03:23:29.470 --> 03:23:32.810 So costs associated with our Wildfire Mitigation Plan, 3542 03:23:32.810 --> 03:23:34.980 costs that appear in our General Rate Case, 3543 03:23:34.980 --> 03:23:36.060 for instance, those are costs 3544 03:23:36.060 --> 03:23:37.560 that would have been required 3545 03:23:37.560 --> 03:23:39.630 irrespective of the Chapter 11. 3546 03:23:39.630 --> 03:23:42.230 Does it include the pending application filed 3547 03:23:42.230 --> 03:23:46.900 on February 7th, 2020 for recovery of 899 million 3548 03:23:46.900 --> 03:23:50.520 for costs recorded in multiple wildfire mitigation 3549 03:23:50.520 --> 03:23:52.970 and catastrophic event memorandum accounts? 3550 03:23:54.000 --> 03:23:55.920 I believe you're referencing our application 3551 03:23:55.920 --> 03:23:57.767 for interim rate relief. 3552 03:23:57.767 --> 03:23:58.767 Uh-huh. 3553 03:23:58.767 --> 03:24:00.770 That would be separate and apart from the Chapter 11, 3554 03:24:00.770 --> 03:24:03.150 and those would be costs that would have been required 3555 03:24:03.150 --> 03:24:06.410 irrespective of the Chapter 11, so yes. 3556 03:24:06.410 --> 03:24:08.860 A simple yes or no is sufficient. 3557 03:24:08.860 --> 03:24:09.693 All right, sorry. 3558 03:24:09.693 --> 03:24:11.080 Does the baseline also include the application 3559 03:24:11.080 --> 03:24:12.830 to recover insurance cost 3560 03:24:12.830 --> 03:24:15.680 in your Wildfire Expense Memorandum Account 3561 03:24:15.680 --> 03:24:20.680 of about 498.7 million also filed February 7th? 3562 03:24:20.770 --> 03:24:21.720 Yes. 3563 03:24:21.720 --> 03:24:23.850 Okay, are you familiar with comparisons 3564 03:24:23.850 --> 03:24:26.680 of California's rates with other states rates? 3565 03:24:27.900 --> 03:24:29.410 Generally speaking, yes. 3566 03:24:29.410 --> 03:24:31.220 Would you agree that California rates tend 3567 03:24:31.220 --> 03:24:34.310 to be higher than the rates of other states? 3568 03:24:37.410 --> 03:24:39.240 Yes, generally. 3569 03:24:39.240 --> 03:24:41.740 You used to be a commissioner in another state, correct? 3570 03:24:41.740 --> 03:24:43.940 I did. Missouri, right? 3571 03:24:43.940 --> 03:24:45.442 That's right. 3572 03:24:45.442 --> 03:24:47.250 Okay, do you recall whether California rates 3573 03:24:47.250 --> 03:24:49.770 are higher than Missouri's rates? 3574 03:24:51.210 --> 03:24:53.380 So I do recall that California's rates 3575 03:24:53.380 --> 03:24:55.670 are higher than Missouri's rates. 3576 03:24:55.670 --> 03:24:58.450 And if you're an industrial customer who uses a lot 3577 03:24:58.450 --> 03:25:03.450 of power on a regular basis, so 24-7, full shifts, 3578 03:25:05.660 --> 03:25:09.890 high load factor, you also have correspondingly high bills 3579 03:25:09.890 --> 03:25:11.990 associated with those high rates, correct? 3580 03:25:12.840 --> 03:25:14.590 Correspondingly or comparatively? 3581 03:25:16.170 --> 03:25:17.947 So compared to Missouri? 3582 03:25:17.947 --> 03:25:19.030 Uh-huh. 3583 03:25:19.030 --> 03:25:21.830 I suspect that would be true since the rates here 3584 03:25:21.830 --> 03:25:23.540 would be higher than the rates in Missouri. 3585 03:25:23.540 --> 03:25:25.240 But I don't recall what the industrial rates 3586 03:25:25.240 --> 03:25:26.842 were in Missouri. 3587 03:25:26.842 --> 03:25:29.240 But comparatively speaking, I think that would be right. 3588 03:25:29.240 --> 03:25:30.073 Thank you. 3589 03:25:30.073 --> 03:25:31.970 Your Honor, I have no further questions. 3590 03:25:31.970 --> 03:25:32.930 Thank you. 3591 03:25:33.814 --> 03:25:35.040 Any recross based on that? 3592 03:25:35.040 --> 03:25:37.510 Yeah, does PG&E evaluate rate impacts 3593 03:25:37.510 --> 03:25:39.550 on customers on the basis of the rate 3594 03:25:39.550 --> 03:25:41.100 or on the average monthly cost? 3595 03:25:42.540 --> 03:25:44.850 So when we look at the cost impact, 3596 03:25:44.850 --> 03:25:46.350 we're looking at the bottom of the bill. 3597 03:25:46.350 --> 03:25:49.480 So it's the bill overall rather than just the rate itself. 3598 03:25:49.480 --> 03:25:53.117 And how does PG&E's average monthly bill rate 3599 03:25:53.117 --> 03:25:56.140 compare in terms of the national average? 3600 03:25:56.140 --> 03:25:58.060 So compared to the national average, 3601 03:25:58.060 --> 03:26:01.100 we're either in line with or actually a little bit lower 3602 03:26:01.100 --> 03:26:02.860 and that's primarily attributable 3603 03:26:02.860 --> 03:26:05.170 to a couple of different issues: The temperate climate, 3604 03:26:05.170 --> 03:26:07.300 but also our leadership around energy efficiency. 3605 03:26:07.300 --> 03:26:09.233 Your Honor, I was asking 3606 03:26:09.233 --> 03:26:11.200 about industrial customer rates. 3607 03:26:11.200 --> 03:26:14.290 Is this specific to industrial customer rates? 3608 03:26:14.290 --> 03:26:15.150 Whatever, I mean, 3609 03:26:15.150 --> 03:26:18.280 this not something we actually need a lot of cross on. 3610 03:26:18.280 --> 03:26:21.730 I mean I think there's plenty of record on this issue. 3611 03:26:21.730 --> 03:26:25.920 So are you done? 3612 03:26:25.920 --> 03:26:26.820 I'm done. 3613 03:26:26.820 --> 03:26:27.653 Okay. 3614 03:26:28.652 --> 03:26:29.674 I assume you don't need to re-cross. 3615 03:26:29.674 --> 03:26:30.870 No, thank you. 3616 03:26:30.870 --> 03:26:32.780 Okay, (mumbles) 3617 03:26:33.940 --> 03:26:35.930 anything else for Mr. Kenney today? 3618 03:26:39.820 --> 03:26:41.590 Any housekeeping things we need 3619 03:26:41.590 --> 03:26:44.840 to take care of before we adjourn for the day? 3620 03:26:44.840 --> 03:26:48.630 I do have one quick question about the timeliness 3621 03:26:48.630 --> 03:26:49.980 of the hearing transcripts 3622 03:26:49.980 --> 03:26:52.610 with the opening brief deadline coming up. 3623 03:26:52.610 --> 03:26:54.860 Well, if I can stop going until five o'clock, 3624 03:26:54.860 --> 03:26:56.725 they can probably get them out faster. 3625 03:26:56.725 --> 03:26:59.970 We only have one so far, Your Honor. 3626 03:26:59.970 --> 03:27:01.470 Okay, well I'm sure the reporters 3627 03:27:01.470 --> 03:27:02.913 are working at it. 3628 03:27:02.913 --> 03:27:04.880 But you know, Judge Cook 3629 03:27:04.880 --> 03:27:09.390 and I have both been really maximizing hearing room time. 3630 03:27:11.450 --> 03:27:14.220 And to the extent that parties wanna keep 3631 03:27:14.220 --> 03:27:17.120 doing cross-examination on stuff that a lot 3632 03:27:17.120 --> 03:27:19.780 of I think is of questionable value to this Commission 3633 03:27:19.780 --> 03:27:22.770 and to briefing, we're gonna have long hearing days 3634 03:27:22.770 --> 03:27:25.030 and it's gonna slow down the transcript. 3635 03:27:25.030 --> 03:27:30.030 So I'm not making any promises on behalf of the reporters. 3636 03:27:30.400 --> 03:27:31.770 I know they work hard and are trying 3637 03:27:31.770 --> 03:27:34.160 to get the transcripts out quickly. 3638 03:27:34.160 --> 03:27:36.660 But if I'm running 9:00 a.m to 12:00 p.m. and 1:00 p.m. 3639 03:27:36.660 --> 03:27:39.360 to 5:00 p.m. that doesn't give them a lot of time 3640 03:27:39.360 --> 03:27:41.230 to get the transcripts ready. 3641 03:27:41.230 --> 03:27:44.310 So I'm sure they're getting them as quickly as they can. 3642 03:27:44.310 --> 03:27:48.700 But, you know, I don't have a huge amount 3643 03:27:48.700 --> 03:27:51.980 of sympathy if I'm having to do this kind of length 3644 03:27:51.980 --> 03:27:53.560 of hearing days to get through stuff 3645 03:27:53.560 --> 03:27:57.190 where frankly there's a lot of stuff that's, 3646 03:27:57.190 --> 03:27:59.050 there's cross-examination here that's not 3647 03:27:59.050 --> 03:28:00.910 on disputed factual issues 3648 03:28:02.370 --> 03:28:04.930 that I think parties could raise in briefs. 3649 03:28:04.930 --> 03:28:09.680 So I won't promise you anything other 3650 03:28:09.680 --> 03:28:11.030 than I'm sure the reporters are trying 3651 03:28:11.030 --> 03:28:13.490 to get the transcripts out as quickly as they can. 3652 03:28:14.690 --> 03:28:16.560 I would start again at 9:00 a.m. 3653 03:28:16.560 --> 03:28:18.910 I am cognizant that it's election day. 3654 03:28:20.796 --> 03:28:23.690 Well actually, we might, last week when I was doing this 3655 03:28:23.690 --> 03:28:25.020 and hoping that we'd be efficient, 3656 03:28:25.020 --> 03:28:28.740 I was thinking maybe we'd start at 10:30. 3657 03:28:28.740 --> 03:28:30.350 But given how it's going, 3658 03:28:30.350 --> 03:28:32.450 we'll start at 9:30 a.m. tomorrow morning. 3659 03:28:33.670 --> 03:28:34.590 Anything else? 3660 03:28:35.820 --> 03:28:36.653 Thank you. 3661 03:28:36.653 --> 03:28:38.590 The hearing is adjourned for the day. 3662 03:28:38.590 --> 03:28:39.423 Off the record. 3663 03:28:40.500 --> 03:28:41.650 Can we go over.