CPUC Docket - Online Documents

PREPARED TESTIMONY OF

ERIC BORDEN

ADDRESSING THE REASONABLENESS OF PACIFIC GAS AND ELECTRIC’S 2020 VEGETATION MANAGEMENT BALANCING ACCOUNT OVERSPEND

Submitted on Behalf of

THE UTILITY REFORM NETWORK

785 Market Street, Suite 1400 San Francisco, CA 94103

Telephone: (415) 929-8876 Facsimile: (415) 929-1132

May 24, 2022

CPUC Docket: A.21-09-008 Witness: Borden, Eric Exhibit: TURN-01

TABLE OF CONTENTS

I. INTRODUCTION .......................................................................................................................... 1 II. ENHANCED VEGETATION MANAGEMENT ....................................................................... 4

A. PG&E’s Overspend on its EVM Program Was Not Reasonably Incurred ......................... 5 III. ROUTINE VEGETATION MANAGEMENT ............................................................................ 6

A. Costs for Higher Time and Equipment Rates and Increased Tree Work Volume Should be Disallowed .......................................................................................................................... 9

B. Additional Costs Incurred Due to SB 247 May be Partially Recovered For Routine Vegetation Management ................................................................................................... 14

C. PG&E Does Not Demonstrate the Reasonableness of Routine Vegetation Management Safety Oversight and Verification Costs ........................................................................... 15

APPENDIX 1 .................................................................................................................................... APP1-1

APPENDIX 2 .................................................................................................................................... APP2-1

APPENDIX 3 .................................................................................................................................... APP3-1

LIST OF FIGURES Figure 1. Cost in Excess (Savings) by Cost Category for Routine VM Compared to Forecast ($ Thousands) ...................................................................................................................................... 8 Figure 2. Northern Sierra Precipitation ......................................................................................... 12

Figure 3. Trees Worked in Routine Vegetation Management Program, 2016-2020 .................... 13

LIST OF TABLES

Table 1. Summary of TURN’s Cost Disallowance Recommendations ($ Thousands) .................. 4 Table 2. PG&E vs. TURN Routine Vegetation Management Costs ($ Thousands) ...................... 9

Table 3. Incremental Routine VM Costs Due to SB 247 .............................................................. 14

I. INTRODUCTION

On November 8, 2018, the failure of a C-hook, a piece of equipment on one of PG&E’s 1

transmission towers, resulted in one of the most catastrophic wildfires in California history. The 2

Commission’s Safety and Enforcement Division (SED) Report on the incident found the utility 3

was out of compliance with the Commission’s regulations because the equipment was 4

improperly inspected, improperly maintained, and improperly replaced or reinforced.1 The 5

failure of the C-hook resulted in the tragic death of 85 residents of Paradise and massive 6

ecological and financial damages. Since then, California utilities have been on an entirely 7

different trajectory to address the risk of utility-caused wildfires compared with years past. 8

Whether that trajectory will be to the benefit of ratepayers remains to be seen. 9

10

In this Application, Pacific Gas and Electric (PG&E) seeks recovery of costs recorded in 2020 to 11

its Wildfire Memorandum Balancing Account (WMBA) and Vegetation Management Balancing 12

Account (VMBA) beyond the amounts approved by the Commission in its last General Rate 13

Case (GRC). In PG&E’s 2020 GRC, the Commission authorized PG&E to seek recovery of 14

expenditures beyond 120% of authorized amounts for the VMBA and 115% of authorized for the 15

WMBA, subject to reasonableness review.2 PG&E accordingly seeks recovery of $155 million 16

in expense recorded to the WMBA and $592 million in expense recorded to the VMBA in 2020.3 17

PG&E spent 228% of what was authorized for the VMBA and 394% of what was authorized for 18

the WMBA, a total of $858 million in overspending.4 19

20

It is important to keep in mind that PG&E’s WMBA and VMBA recorded costs do not represent 21

a complete accounting of all of PG&E’s wildfire risk mitigation expenditures in 2020. PG&E 22

has requested reasonableness review of other 2020 wildfire mitigation costs recorded to the Fire 23

Risk Mitigation Memorandum Account (FRMMA) and Wildfire Mitigation Plan Memorandum 24

1 D.20-05-019, p. 11. 2 D.20-12-005, Ordering Paragraph 1(a)-(b). 3 PG&E Testimony, Table 1-1, p. 1-6 (5/19/22 Errata). 4 PG&E Testimony, p. 1-7, Tables 1-4 and 1-5.

2

Account (WMPMA) in its Test Year 2023 General Rate Case.5 Those costs include 2020 1

WMPMA recorded costs of $326 million in capital and $65 million in expense, plus 2020 2

FRMMA recorded costs of $41,000 in capital and $6 million in expense.6 3

4

PG&E presents its WMBA and VMBA costs to the Commission as reasonable when measured 5

against customer benefits, including reducing wildfire risk and increasing public safety.7 But the 6

reality is that PG&E continued to improperly manage its vegetation management programs while 7

residents and firefighters suffered from deadly and destructive wildfires.8 Leaving ratepayers to 8

foot the bill for ineffective mitigation is unacceptable, nor is it acceptable to pass through costs 9

that have not been demonstrated to be reasonable. PG&E was already authorized ratepayer funds 10

for these activities in its 2020 GRC, plus a 15-20% buffer, which PG&E blew past. PG&E chose, 11

in its inability to control its budget to what was authorized, to take on the risk of these costs – it 12

is not ratepayers’ responsibility to bail out the utility unless the costs were reasonably incurred. 13

14 TURN thus urges a thorough and robust examination of expenditures sought for recovery from 15

ratepayers here. Simply stating that these expenditures are connected to mitigating wildfire risk 16

is not sufficient justification to grant cost recovery from ratepayers. Virtually all utility activities 17

that affect the overhead electric power system have some connection to mitigation of wildfire 18

5 A.21-06-021, PG&E-04, p. 2-9 (version submitted with PG&E’s application on June 30, 2021). These costs will be the subject of “Track 2” in PG&E’s GRC. See A.21-06-021 Assigned Commissioner’s Scoping Memo and Ruling, 10/1/21, p. 12. 6 A.21-06-021, PG&E-04, p. 2-AtchA-1 (version submitted with PG&E’s application on June 30, 2021). PG&E subsequently modified PG&E-04 to remove this portion of its testimony addressing reasonableness review of 2020 WMPMA and FRMMA costs, pending the initiation of Track 2 where such costs will be addressed. 7 PG&E Testimony, p. 3-33, lines 16-22. 8 PG&E’s mismanagement of its routine VM and EVM programs may have also led to the 2020 Zogg Fire which is still under investigation. (Order to Show Cause Re Conditions of Probation, USA v. PGE, Doc 1277 (12/29/20), p. 12, lines 5-19, included in Appendix 3 to this testimony). The Zogg Fire occurred on a high-risk circuit (Gervin 1101) that would have likely been worked if PG&E had implemented its EVM program in a risk-informed manner. (See Table 6, EOE Process Corrective Action Plan 90-Day Report, August 4, 2021, p. 15, included in Appendix 3 to this testimony).

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risk, and the Commission adopted limits in the 2020 GRC Decision on the budgets that PG&E 1

should be able to recover without further reasonableness review. 2

3 This testimony focuses solely on the overspend sought for recovery in the utility’s VMBA.9 4

TURN finds and recommends the following based on our analysis and discussion below: 5

• PG&E’s Enhanced Vegetation Management (EVM) program was poorly managed in 6 2020, when the utility continued to address relatively low-risk miles rather than 7 prioritizing the highest risk miles. This has significant safety and cost-effectiveness 8 implications for the program. These actions were found to be improper by the 9 Commission, resulting in placement of the utility in Step 1 of the Enhanced Oversight 10 and Enforcement Process. Cost overruns were thus not reasonably incurred and should be 11 disallowed. 12 13

• Regarding routine vegetation management (VM): 14 15

o Additional costs incurred due to higher unit costs and increased volume of work 16 were not reasonable. PG&E incurred these costs because it shifted VM work from 17 2019 to 2020 due to the scale-up of PG&E’s poorly managed EVM program in 18 2019. Delaying critical routine VM work in 2019 may have led the utility to be 19 out of compliance with VM regulations in 2020. 20 21

o By delaying some 2019 VM work until 2020, PG&E paid 2020 labor rates 22 required by SB 247 for work that otherwise would have been completed at 2019 23 labor rates. TURN does not oppose recovery from ratepayers for a portion of 24 increased costs due to SB 247 for the routine VM program. We oppose the 25 portion of these costs related to work carried over from 2019 for the reasons 26 stated above. 27

28 o TURN opposes cost recovery for Safety Oversight and Work Verification because 29

there is insufficient evidence these additional efforts were effective or the costs 30 were reasonably incurred. 31

32 These findings result in the following disallowance recommendations. 33 34

9 Due to resource constraints, TURN has coordinated its coverage of issues in this proceeding with the Public Advocates Office (Cal Advocates). TURN’s silence on other aspects of PG&E’s request should not be taken as support for PG&E’s proposals.

4

Table 1. Summary of TURN’s Cost Disallowance Recommendations ($ Thousands) 1 2

3 4 TURN discusses these issues in further detail below. 5 6

II. ENHANCED VEGETATION MANAGEMENT

PG&E spent $133 million over the amount authorized by the Commission in D.20-12-005 for 7

Enhanced Vegetation Management (EVM) in 2020.10 PG&E now seeks to recover $69 million 8

of that amount, which is the amount exceeding the reasonableness review threshold (120% of the 9

authorized forecast).11 PG&E states that the 2020 recorded EVM costs were higher than the 10

adopted forecast because of an increase in the unit cost per tree worked.12 PG&E identifies five 11

primary reasons its unit cost for the EVM program was higher than forecast in 2020: 12

13 PG&E’s recorded unit costs for Enhanced VM work were higher than forecast because 14 of: increased volume of tree removals; increased costs for wood management; increased 15 T&E costs [Time and Equipment costs]; costs incurred to comply with new legislation; 16 and additional costs for increased safety oversight and work verification.13 17 18

Upon investigation, PG&E worked 57% fewer trees and accomplished 64% fewer miles than 19

forecast.14 It also did not forecast costs for wood management or safety oversight.15 However, it 20

10 PG&E Testimony, p. 3-2 (calculated as $451.390 million minus $318.742 million). 11 PG&E Testimony, p. 3-20, Table 3-6. 12 PG&E Testimony, p. 3-23. 13 PG&E Testimony, p. 3-24, lines 2-7. 14 TURN-2, Question 16, Attachment 1, included in Appendix 2 to this testimony 15 TURN-2, Question 16, Attachment 1 shows no GRC forecast for these cost categories.

PG&E Request

TURN Recommendation /

Maximum Allowable Recovery

(1)

Difference (TURN-PG&E)

EVM 68,899$ -$ (68,899)$ Routine VM 423,986$ 169,161$ (254,825)$ Total 492,885$ 169,161$ (323,724)$

(1) TURN does not address all cost increase drivers of routine VM.

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spent 137% more than forecast for each tree “worked” (trimmed or removed) due primarily to 1

higher T&E (Time and Equipment) rates that had to be negotiated rather than lower unit cost 2

contracts “needed to increase the vendor pool and complete the higher volume of work.”16 3

Additional costs compared with the 2020 forecast were also incurred due to SB 247 which 4

increased vegetation management labor costs. 5

A. PG&E’s Overspend on its EVM Program Was Not Reasonably Incurred

PG&E’s testimony neglects to mention PG&E’s extremely poor EVM performance in 2020, 6

which resulted in the Commission’s placement of PG&E into Step 1 of the Enhanced Oversight 7

and Enforcement (EOE) Process. Specifically, the Commission found that PG&E continued 8

deployment of EVM as it had in 2019 by completing relatively low-risk miles rather than a 9

concerted effort to maximize the safety benefits of the program, stating: 10

11 PG&E is not sufficiently prioritizing its Enhanced Vegetation Management (EVM) based 12 on risk. PG&E ranks its power line circuits by wildfire risk, but the work performed in 13 2020 demonstrates that PG&E is not making risk-driven investments. PG&E is not doing 14 the majority of EVM work – or even a significant portion of work – on the highest risk 15 lines. 16 17 In 2020, PG&E conducted more work in 2020 on lower risk power lines than high risk 18 lines if one examines the 161 power lines on which PG&E performed EVM. Less than 19 five percent of the EVM work PG&E completed was on the 20 highest risk power 20 lines according to PG&E’s own risk rankings.17 21 22

The Commission further emphasized, “Simply put, PG&E failed to risk-prioritize its EVM work 23

on the ground, as is apparent from an analysis of the EVM work performed under any of the [risk 24

modeling] results.”18 25

16 PG&E Testimony, p. 3-14, lines 18-19. 17 Resolution M-4852, p. 7 (emphasis added). 18 Resolution M-4852, p. 7.

6

As District Court Judge Alsup, who oversaw PG&E’s probation, stated, “PG&E failed to use risk 1

models as ‘the predominant input . . . in PG&E’s [EVM] work planning and execution for 2019 2

and 2020.’ This choice by PG&E defies belief.”19 3

4

It would further defy belief to allow PG&E to collect cost overruns for a program that was not 5

properly managed and conducted. PG&E’s 2020 EVM cost overruns were not reasonably 6

incurred, and should be denied in full. Ratepayers have already paid nearly $400 million for 7

EVM in 2020.20 They should not pay a cent more. 8

III. ROUTINE VEGETATION MANAGEMENT

PG&E spent 200% more than its authorized routine vegetation management budget and now 9

requests $424 million additional funds from ratepayers for this work.21 PG&E identifies 5 10

primary drivers of this overspend: 11

12 1. Increased unit costs. These were primarily due to out of state contracting and move to 13

Time and Equipment (T&E) rather than unit cost contracts “needed to increase the 14 vendor pool and complete the higher volume of work. This switch was driven by the need 15 to complete the higher volume of work coupled with a significant market demand for tree 16 contractors in California.”22 This resulted in a recorded unit cost of $448 per tree 17 “worked” (trimmed or removed) versus an imputed $204 per tree worked that was 18 authorized by the Commission.23 19 20

2. Increased volume of work. PG&E worked an additional 434,000 trees more than 21 forecast24 due to delaying routine work from 2019 to 2020 to accomplish EVM.25 22 Additionally, PG&E claims higher precipitation in 2019 that “led to higher tree volumes 23 in 2019 that contributed to the increased volume of tree work completed in 2020.”26 24

19 USA v. PGE, Doc 1277 (12/29/20), p. 16 (emphasis added) (quoting and reacting to the Federal Monitor’s December 16, 2020 Letter, USA v PGE, Doc 1277-1, included in Appendix 3 to this testimony). 20 PG&E Testimony, p. 3-20, Table 3-6 (showing the “adopted at 120%” amount of $382.491 million). 21 PG&E Testimony, p. 3-7, Table 3-3. 22 PG&E Testimony, p, 3-14, line 19-21. 23 PG&E Testimony, p. 3-16, Table 3-5. 24 PG&E Testimony, p. 3-17, line 3. 25 PG&E Testimony, p. 3-17, lines 15-17. 26 PG&E Testimony, p. 3-16-17, lines 22-2.

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PG&E also claims its equipment inspection program WSIP (Wildfire Stafety Inspection 1 Program) resulted in additional work for tree contractors.27 2 3

3. Increased labor costs due to SB 247. SB 247 was adopted in October 2019 and generally 4 boosted wages for tree trimmers, which was not forecast by the utility in the 2020 GRC.28 5 6

4. Additional costs for safety oversight, quality verification, and quality assurance. PG&E 7 did not include these costs in its 2020 forecast.29 8 9

5. Increased costs for environmental reviews.30 10 11

PG&E also points to a change from a cash to accrual accounting basis for the VMBA, which 12

impacted only Routine VM, and higher vegetation control spending, plus cost reductions from 13

in-sourcing of inspectors and Legacy Public Safety and Reliability work.31 14

15 The following graphic shows the breakdown of cost overruns by cost driver according to PG&E. 16 17

27 PG&E Testimony, p. 3-17, lines 3-14. 28 PG&E Testimony, p. 3-17, lines 22-33. 29 PG&E Testimony, p. 3-18, lines 7-8. 30 PG&E Testimony, p. 3-18, line 9. 31 PG&E Testimony, p. 3-18 – 3-19.

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1 Figure 1. Cost in Excess (Savings) by Cost Category for Routine VM Compared to Forecast ($ 2

Thousands)32 3 4

5 6 As discussed below, TURN finds cost overruns related to higher unit costs and volume were not 7

reasonably incurred and disallowed. Though the Commission could find that compliance failures 8

related to 2020 VM work necessitate the disallowance of all routine VM cost overruns, TURN 9

conservatively does not oppose a portion of SB 247-related labor costs that are unrelated to the 10

higher volume of work (relative to forecast) in 2020. 11

12

Our disallowance recommendations are summarized in the Table below and discussed further in 13

the ensuing sections. 14

15

16

17

18

19

32 TURN-2, Question 10, Attachment 1, included in Appendix 2 to this testimony; PG&E Testimony, p. 3-14, Table 3-4.

$198,499

$112,205

$81,952

$42,600

$13,700 $5,417 $3,113

$(33,500)

SB 247 Higher T&E IncreasedVolume of Work

Cash to AccrualBasis

VegetationControl

Safety Oversight EnvironmentalActivities

Insourcing andLegacy

9

Table 2. PG&E vs. TURN Routine Vegetation Management Costs ($ Thousands)33 1 2

3

A. Costs for Higher Time and Equipment Rates and Increased Tree Work Volume Should be Disallowed

PG&E does not demonstrate the reasonableness of higher unit costs incurred in 2020. First, the 4

utility’s claim that it put off routine VM work to accomplish EVM is fraught. EVM work 5

accomplished in 2019 was not accomplished on a risk-informed basis, resulting in relatively little 6

safety benefits in comparison with high costs for this program incurred in this year. As stated by 7

the Federal Monitor: 8

9 PG&E completed the majority of its 2019 EVM work in relatively low risk portions 10 of its high fire-threat districts (“HFTDs”). Put another way, as the Company pushed 11 to meet its 2,455-mile EVM target for 2019, it did not prioritize wildfire risk 12 reduction according to its risk model. PG&E had previously represented that it 13 prioritized 2019 EVM work based on a risk model the Company developed with a third-14 party consultant, which assigned a risk score for each HFTD circuit. The Company also 15 highlighted that its EVM plan prioritized higher-risk mileage in the multi-year EVM 16 program to achieve the greatest risk reduction sooner rather than later in the plan 17 lifecycle. Despite the fact that the top 100 circuits on the risk model had significantly 18 higher risk scores than the remaining 596 circuits ranked in the model, approximately 19 59% of PG&E’s completed 2019 EVM mileage was outside of the top 100 circuits. Of 20 course, operational considerations may force some deviations from any risk model or 21 related plan informed by that model, but in this case, the severity of the deviations 22

33 PG&E’s figures and TURN calculation from TURN-2, Question 10, Attachment 1.

PG&E RequestTURN

RecommendationDifference

(TURN-PG&E)SB 247 198,499$ 143,248$ (55,251)$ Higher T&E 112,205$ -$ (112,205)$ Increased Volume of Work 81,952$ -$ (81,952)$ Cash to Accrual Basis 42,600$ Not addressedVegetation Control 13,700$ Not addressedSafety Oversight 5,417$ -$ (5,417)$ Environmental Activities 3,113$ Not addressedInsourcing and Legacy Public Safety (33,500)$ (33,500)$ Total / Maximum Recovery Allowed (TURN) 423,986$ 169,161$ (254,825)$

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strongly suggest that the Company prioritized the achievement of EVM mileage 1 targets over the most meaningful wildfire risk reduction.34 2

3 This is exactly the same issue for which the Commission placed PG&E in Step 1 of the EOE 4

Process in 2020.35 5

6

This is not a case where PG&E reasonably deferred lower priority work in 2019 in order to 7

deliver critical safety benefits for its customers from completing higher priority work that year. 8

Rather, PG&E deferred necessary public safety work in order to spend money on the 9

achievement of EVM mileage targets, rather than meaningful wildfire risk reduction. PG&E was 10

funded to conduct routine VM in 2019 based on representations that this work was needed to 11

“Protect the public from fires caused by trees falling into high-voltage distribution lines” and 12

“Comply with CPUC and California Department of Forestry and Fire Protection (CAL FIRE) 13

regulations,” among other purposes.36 Had PG&E instead delivered incremental and, most 14

importantly, meaningful wildfire risk reduction benefits from EVM that year, TURN might view 15

PG&E’s deferred routine VM costs differently. However, under the circumstances at hand, 16

ratepayers should not have to pay again for units of routine VM work planned for 2019 but 17

displaced by PG&E’s poorly implemented EVM program. 18

19 Further, delaying critical routine VM work may have led PG&E to be out of compliance with 20

regulatory requirements, which has major safety implications, in addition to the consideration of 21

reasonableness. The District Court, through investigations by the Federal Monitor and findings 22

by PG&E itself, discovered routine vegetation management compliance failures in 2020. The 23

District Court noted various “gaps in PG&E’s compliance with California law, recordkeeping, 24

and compliance with various terms of its probation,” including among others:37 25

34 Order Re Monitor Letter, USA v PGE, Doc 1247-1 (10/20/20), p. 2, included in Appendix 3 to this testimony, (regarding Federal Monitor update on PG&E’s vegetation management and infrastructure inspection operations since 2019) (emphasis added). 35 See Section II.A and fn 17, supra. 36 A.15-09-001 (PG&E 2017 GRC), PG&E-04, pp. 7-2 – 7-3. In D.17-05-013, the Commission resolved PG&E’s 2017 GRC by adopting a settlement agreement (with modifications) that fully funded PG&E’s vegetation management request. See D.17-05-013, pp. 57-58, 62. 37 USA v. PGE, Doc 1277 (12/29/20), p. 14.

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• “[…]PG&E continues to be in violation of Section 4293 because it has failed to 1 remove all trees and limbs within the required clearances.”38 2 3

• “[…] in 2020, PG&E continued to allow trees to threaten distribution lines in 4 violation of California law. PG&E found 157 “Level 1” trees (posing imminent 5 threats to distribution lines), between January and April 2020. PG&E violated GO 95 6 by failing to ameliorate these hazardous trees within 24 hours. Then there are the 7 trees that PG&[E]’s work failed to address. On lines certified ‘compliant,’ PG&E’s 8 internal reviews found 432 trees that failed. The Monitor’s independent, and 9 smaller-scope review found an additional 153 dangerous tree conditions.”39 10 11

• “[…] there ‘continue to be gaps in PG&E’s recordkeeping’ of inspections and 12 vegetation work… ‘approximately 8,200 trees’ displayed risk ‘scores indicating’ they 13 should be removed, but were nonetheless ‘marked in the internal system as not 14 requiring tree work.’”40 15

16 PG&E’s other claim, that higher precipitation levels in 2019 caused a higher volume of trees 17

needing to be worked than the past, is unproven by PG&E and impossible to disaggregate from 18

the deferral of 2019 VM work discussed above. Indeed, the simplistic correlation of one year’s 19

precipitation level to the next year’s tree work is likely more complex than presented by PG&E. 20

As displayed below, October 2016 to October 2017 was one of the wettest years in PG&E’s 21

service territory on record, exceeding precipitation levels in 2019, yet trees worked in 2018 were 22

far less than 2020. 23

38 Id. 39 Id. (emphasis added). 40 Id. at 15.

12

Figure 2. Northern Sierra Precipitation41 1

2 3

41 Links to water precipitation data in PG&E’s service territory provided by PG&E in TURN-2, Question 12, included in Appendix 2 to this testimony. While the Figure above shows Northern Sierra precipitation for 2016-2017, 2016-2017 was the 2nd wettest year on record in the San Joaquin Basin, and the 2nd wettest year in the Tulare Basin.

2016-2017

2018-2019

13

Figure 3. Trees Worked in Routine Vegetation Management Program, 2016-202042 1 2

3 4

Additionally, 2017-2018 experienced very low levels of precipitation,43 so if the correlation 5

proffered by PG&E were true, 2019 should have had a very low level of tree work. It is therefore 6

a reasonable assumption that the large increase of trees worked in 2020 was due solely or 7

primarily to deferred routine work from 2019, regardless of precipitation levels. TURN finds that 8

deferral of this work was not reasonable because it was due to implementation of a poorly 9

managed 2019 EVM program and may have led to PG&E falling short of regulatory compliance 10

in 2020. 11

12

These issues are inextricably linked with unit cost overruns. Had PG&E not delayed its 2019 13

compliance work to 2020, it would have accomplished routine VM at a significantly lower unit 14

cost of $257 per tree in 2019, rather than $420 per tree in 2020.44 Furthermore, PG&E may not 15

have needed to sign exorbitantly priced contracts to complete a higher volume of work for 16

routine VM if it had managed its 2019 workload properly. 17

18

42 PG&E GRC Workpaper Table 9-10, included in Appendix 3 to this testimony. 43 Links to water precipitation data in PG&E’s service territory provided by PG&E in TURN-2, Question 12. 44 PG&E GRC Workpaper Table 9-10.

1,078,049

1,264,300 1,324,331 1,273,796

1,560,055

2016 2017 2018 2019 2020

14

On balance, PG&E presents a wholly insufficient rationale that rateapayers should be required to 1

pay for cost overruns from higher T&E rates and volume of work; the request should be denied. 2

B. Additional Costs Incurred Due to SB 247 May be Partially Recovered For Routine Vegetation Management

While PG&E unreasonably incurred additional costs for a portion of the utility’s routine VM 3

work in 2020 that was deferred from 2019, additional costs due to newly adopted legislation 4

were unforeseen by the utility at the time of its forecast and had to be incurred to accomplish the 5

remainder of the utility’s work in 2020. While a stricter approach to reasonableness may lead the 6

Commission to disallow all cost overruns in the routine VM program due to compliance failures 7

discovered in 2020, TURN conservatively does not oppose recovery from ratepayers for some 8

amount od reasonably incurred SB 247 costs, which we define here as incremental unit costs for 9

the portion of work that was forecast in 2020 (as opposed to work that was deferred during 2019 10

and carried over to 2020). This is calculated below using PG&E’s assumptions for the impact on 11

unit cost increases due to SB 247. 12

13 Table 3. Incremental Routine VM Costs Due to SB 247 14

15 Additional Cost per Tree for SB 247 (1) $ 127 Trees Forecast for 2020 Routine VM (2) 1,125,826 Total SB 247 Costs $ 143,248,186 (1) PG&E Assumption. TURN-2, Question 10, Attachment 1. (2) PG&E Testimony, p. 3-16, Table 3-5.

16 17 Therefore, TURN does not oppose $143 million of the $198 million PG&E seeks for additional 18

costs due to the passage of SB 247 for routine VM. By contrast, TURN opposes recovery for any 19

SB 247 related costs for the EVM program as these are indistinguishable from the poor 20

management, oversight, and implementation of this program in 2020 that has been well-21

documented by the Commission. 22

23

24

15

C. PG&E Does Not Demonstrate the Reasonableness of Routine Vegetation Management Safety Oversight and Verification Costs

PG&E states that it overspent its routine VM budget for safety oversight and verification work 1

because: 2

3 PG&E introduced quality verification audits in 2020. The costs for this work were not 4 included in the 2020 GRC forecast.45 5 6

PG&E further clarified for TURN that its 2020 GRC forecast included “Contractor Safety and 7

Quality Assurance,” while its 2020 work included “Safety Oversight, Quality Verification and 8

Quality Assurance.”46 PG&E spent $5 million on the “quality verification audits” work, of 9

which it seeks to recover $4.4 million here related to distribution work.47 All in all, “PG&E 10

forecast $3.6 million, recorded $9.0 million and is seeking to recovery $5.4 million for the 11

Combined Safety Oversight, Quality Verification and Quality Assurance.”48 12

13

However, as described above, PG&E was found to be out of compliance with regulatory standards 14

for at least a portion of its system in 2020. PG&E presents no evidence that its additional efforts 15

regarding quality control and verification were effective, just that the costs were incurred. 16

Therefore, PG&E does not present sufficient evidence its costs were reasonably incurred and 17

should be recovered from ratepayers. 18

19

To be clear, TURN does not oppose this type of work, as we believe quality control is among the 20

most important types of work to mitigate the risk of compliance failures and ignitions -- just as 21

we do not oppose routine VM or EVM per se. However, given the utility’s description of these 22

cost overruns and the lack of compliance with regulatory standards in 2020, PG&E has not 23

demonstrated the cost overspend here was reasonable. 24

45 PG&E Testimony, p. 3-18, lines 5-8. 46 TURN-2, Question 15 Supplemental 01, included in Appendix 2 to this testimony. 47 TURN-2, Question 15 Supplemental 01. 48 TURN-2, Question 15 Supplemental 01.

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APPENDIX 1

Eric Borden Statement of Qualifications EDUCATION Master of Public Affairs, University of Texas at Austin, LBJ School of Public Affairs, 2010-2012 Specialization: Natural Resources and the Environment Thesis: Electric Vehicles and Public Charging Infrastructure in the United States

B.S.B.A., Washington University in St. Louis, Olin School of Business, 2002-2006 Majors: Finance, Entrepreneurship Minor: Psychology PROFESSIONAL EXPERIENCE Energy Policy Analyst February 2015 – Present The Utility Reform Network (TURN) • Prepare testimony, conduct analyses, draft comments, and represent TURN in various

proceedings at the California Public Utilities Commission (CPUC) related to general rate cases, wildfire-related safety applications, electric vehicle charging infrastructure, utility procurement, rate design, and demand response.

Senior Energy Analyst June 2013 – January 2015 4 Thought Energy LLC, Chicago, IL 4 Thought Energy specializes in designing, installing, and operating on-site natural gas combined heat and power (CHP) systems. • Created financial models to forecast profits of potential site installations • Researched state and regional public policy frameworks governing CHP • Conducted analyses over electricity and natural gas price trends • Developed presentations and marketing materials for investor meetings

Consultant February 2014 – October 2014 International Renewable Energy Agency (IRENA), Bonn, Germany • Hired to write a report on worldwide electricity sector battery storage, including primary

applications for renewable energy integration, market developments, trends, and case studies • Conduct research, review literature, interview key industry players, develop case study

material • Travel to Bonn, company sites, and research facilities • Written report will be sent to policymakers in 167 IRENA member countries

German Chancellor Fellow July 2012 – November 2013 Alexander von Humboldt Foundation, hosted by DIW Berlin, Berlin, Germany

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Research Project Title: “Energy Storage Technology and the Large-Scale Integration of Renewable Energy” • Investigated the role of energy storage in Germany for renewable integration through

literature review, interviews with German energy experts, and analysis comparing public policy support in Germany and the U.S. for storage technologies

• Invited to hold a presentation at the International Renewable Energy Storage Conference and Exhibition (IRES 2013)

• Discussions with German businesses and governmental ministries; special visit to European Union and NATO headquarters in Brussels

• Attended energy conferences and workshops in Berlin Senior Consultant June 2008-July 2009 The Kenrich Group LLC, Chicago, IL • Consulted for multiple energy utilities in legal disputes with the Department of Energy (DOE) • Performed detailed research and quantitative/qualitative analysis to analyze financial impact

related to construction of coal-fired power plants, liquid natural gas facilities, and other types of construction

• Contributed to final reports and presentations submitted in arbitration, settlement, or court of law presenting KRG’s expert opinion

Associate, Intellectual Property Charles River Associates, Chicago, IL

July 2006 – May 2008

• Developed complex financial models including discounted cash flow, lost profit, and regression analyses to support expert reports within the context of intellectual property and financial litigation in multiple industries

• Created valuation models and supporting materials to value business entities • Contributed to final reports and presentations submitted in arbitration, settlement, or court of

law presenting CRA’s expert opinion

PUBLICATIONS “Clean Energy Technology and Public Policy,” LBJ Journal of Public Affairs, editor and contributor, 2011. “Electric Vehicles and Public Charging Infrastructure: Impediments and Opportunities for Success in the United States,” The University of Texas at Austin, 2012. “Policy efforts for the development of storage technologies in the U.S. and Germany,” DIW Discussion Paper, 2013. “Expert Views on the Role of Energy Storage for the German Energiewende,” DIW Berlin and BMU “Stores” project, online here, 2014. “Germany’s Energiewende,” chapter 15 in Global Sustainable Communities Design Handbook, ed. Dr. Woodrow Clark, Elsevier Press, 2014. “Battery Storage for Renewables: Market Status and Technology Outlook,” International Renewable Energy Agency (IRENA), co-author with Ruud Kempener, 2015.

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EXPERT TESTIMONY

Date Proceeding Testimony

4/13/15 A.14-04-014/ R.13-11-007

Testimony Regarding SDG&E’s Application 14-04-014 for Authority to Build Electric Vehicle Charging Infrastructure

5/15/15 A.14-11-003 Direct Testimony Addressing the Treatment of Solar Distributed Generation for Estimating Distribution System Capacity/Expansion Expenditures

11/30/15 A.15-02-009 Testimony Regarding PG&E’s Supplement to A.15-02-009 for EV Infrastructure and Education Program

12/21/15 A.15-02-009 Rebuttal Testimony Regarding PG&E’s A.15-02-009 for EV Infrastructure and Education Program

4/29/16 A.15-09-001 Testimony Addressing the Proposal of PG&E for Electric Distribution and New Business Expenditures

4/19/17 R.12-06-013 Testimony Evaluating Hardship due to TOU Rates on Vulnerable Populations in Hot climate Zones

7/25/17 A.17-01-020 Testimony Addressing the Proposal of PG&E for a Fast Charging Infrastructure Program

10/26/18 A.17-12-011 Testimony Regarding Potential Effects of More “Cost Based” TOU Rates and Seasonal Differentiation of Tiered Rates.

11/30/18 A.18-06-015 Testimony Addressing SCE’s Charge Ready 2 EV Infrastructure Proposal

12/21/18 A.18-06-015 Rebuttal Testimony Addressing SCE’s Charge Ready 2 EV Infrastructure Proposal

4/23/19 A.18-09-002 Testimony Addressing SCE’s Grid Safety and Reliability Program Infrastructure Proposal

7/26/19 A.18-12-009 Testimony Addressing Pacific Gas and Electric’s Enhanced Vegetation Management and System Hardening Wildfire Mitigation Expenditures.

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5/5/20 A. 19-08-013 Testimony Addressing Southern California Edison’s Test Year 2021 General Rate Case Wildfire Management, Wildfire Risk, Vegetation Management, and New Service Connection Policy Issues and Cost Forecasts

5/18/20 A.19-10-012 Testimony Addressing San Diego Gas and Electric’s Power

Your Drive Electric Vehicle Infrastructure Program

9/4/20 A.19-08-013 Testimony Addressing SCE’s 2021 Track 2 General Rate Case Wildfire Memorandum Account Request

4/14/21 A.20-09-019 Prepared Testimony Addressing Pacific Gas and Electric’s Wildfire Mitigation Memorandum Accounts

3/2/22 A.21-10-010 Prepared Testimony Addressing Pacific Gas and Electric’s

Electric Vehicle Charge 2 Proposal

3/30/22

A.21-06-022 Prepared Testimony Addressing Pacific Gas and Electric’s Framework for Substation Microgrid Solutions

Appendix 2

Data Requests Relied Upon

2021WMCE_DR_TURN_002-Q10 Page 1

PACIFIC GAS AND ELECTRIC COMPANY 2021 Wildfire Mitigation and Catastrophic Events

Application 21-09-008 Data Response

PG&E Data Request No.: TURN_002-Q10 PG&E File Name: 2021WMCE_DR_TURN_002-Q10 Request Date: April 29, 2022 Requester DR No.: A21-09-008_TURN_DR_PG&E-

01_4-29-22 Date Sent: May 11, 2022 Requesting Party: The Utility Reform Network PG&E Witness: Kamran Rasheed Requester: Hayley Goodson

SUBJECT: VMBA, WMBA

Vegetation Management Balancing Account

QUESTION 10

PG&E Testimony, p. 3-14, states

“PG&E’s recorded costs for Routine VM tree work were approximately $401.2 million higher than the forecast amount due to: increased costs per unit of work; increased volume of work; additional costs for complying with new legislation; additional costs for safety oversight; and increased costs for environmental activities.”

For each of these factors please quantify, in both percentage and dollar terms, the impact of the factor. Please provide an explanation and supporting workpapers in Excel with all calculations and assumptions.

ANSWER 10

See attachment 2021WMCE_DR_TURN_002-Q10Atch01.

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2021 WMCE_DR_TURN_002-Q10Atch01

Category Forecast Cost (A) Recorded Cost Cost DifferencePercentage Increase Assumptions

Increased Costs per Unit of Work (Routine Regulatory Compliance + EEVM Legacy PS&R)185,081$ 290,092$ 112,205$ 28% Additional costs due to higher costs for time and materials workIncreased Volume of Work -$ 81,952$ 81,952$ 20% Based on 434,229 additional trees worked at forecast cost of $188.73/treeAdditional Costs for Complying with New Legislation -$ 198,499$ 198,499$ 49% SB247 Legislation resulted in a 49% labor cost increase. See Note (A)Subtotal - Increased Costs for Tree Work 185,081$ 570,543$ 392,656$ Additional Costs for Safety Oversight 3,579$ 8,996$ 5,417$ 1%Increased Costs for Environmental Activities 2,840$ 5,953$ 3,113$ 1%Total 191,500$ 585,492$ 401,186$

(A) Costs for SB2472019 Recorded Cost per Tree Worked 259.67$ SB247 Labor Premium 49%Additional Cost per Tree for SB247 127.24$ Recorded Trees Worked in 2020 1,560,055 Additional Cost for SB247 198,498,746$

PG&E, in partnership with an external vendor, performed a 2019 versus 2020 Rate Analysis and determined that the SB247 impact was approximately 49%. The 49% SB247 impact represents the overall price change due to implementing SB247 and includes both the increase in the prevailing wage rate for qualified line clearance tree trimmers and other cost elements.

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SUBJECT: VMBA, WMBA


QUESTION 12

PG&E Testimony, pp. 3-16 - 3-17, states

“The above-normal precipitation in 2019 led to higher tree volumes in 2019 that contributed to the increased volume of tree work completed in 2020.”

a. Please define “above-normal precipitation” as used in this sentence and provide all data and sources that show there was “above-normal precipitation” in 2019.

b. Please provide the total amount of precipitation in PG&E’s service territory from 2010-2021 on an annual basis. Please provide in Excel with an explanation and supporting sources and calculations.

ANSWER 12

a. “WMCE-2021-PhI_DR_TURN_002-Q12Atch01” as published by California Department of Water Resources provides the Hydroclimate Report for Water Year 2019. This report defines and describes the conditions referenced in PG&E Testimony, pp. 3-16 - 3-17.

See for example, page 2 that states: “The WY [water year] 2019 ended with 139 percent of average precipitation in the Northern Sierra and 168 percent of average April-July stream flow in the Sacramento River and 171 percent of average for the San Joaquin River. Peak statewide snowpack was 175 percent of average marking the fifth largest snowpack with records dating back to 1950.”

b. PG&E utilizes California Department of Water Resources, “California Data Exchange Center” reports for three regions to estimate annual precipitation totals for the service territory. This resource reports recorded annual precipitation for the years requested.

Northern Sierra

https://cdec.water.ca.gov/precipapp/get8SIPrecipIndex.action

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San Joaquin Basin


Tulare Basin https://cdec.water.ca.gov/precipapp/get6SIPrecipIndex.action

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2021WMCE_DR_TURN_002-Q15Supp01 Page 1



PG&E Data Request No.: TURN_002-Q15 PG&E File Name: 2021WMCE_DR_TURN_002-Q15Supp01 Request Date: April 29, 2022 Requester DR No.: A21-09-008_TURN_DR_PG&E-

01_4-29-22 Date Sent: May 13, 2022

Supp01: May 23, 2022

Requesting Party: The Utility Reform Network

PG&E Witness: Kamran Rasheed Requester: Hayley Goodson

SUBJECT: VMBA, WMBA


QUESTION 15

Re PG&E Testimony, p. 3-18, please provide the dollar amount sought for “quality verification audits” of VM work in 2020. Please provide in Excel with all supporting workpapers, calculations, and assumptions.

ANSWER 15 SUPPLEMENTAL 01

2021WMCE_DR_TURN_002-Q15Supp01Atch01 is an Excel file that includes the 2020 recorded costs for quality verification audits. The file includes the costs for both distribution and transmission work. The total recorded for quality verification audits is:

Distribution $4,386,847

Transmission $597,830

Total $4,984,677

PG&E is seeking to recover only the distribution costs in this proceeding.

ANSWER 15

PG&E’s forecast in the 2020 GRC included Contractor Safety and Quality Assurance. Ultimately, the work that PG&E conducted in 2020 included Safety Oversight, Quality Verification and Quality Assurance. In total, PG&E forecast $3.6 million, recorded $9.0 million and is seeking to recover $5.4 million for the combined Safety Oversight, Quality Verification and Quality Assurance (see 2021WMCE_DR_TURN_002-Q10Atch01).

2021WMCE_DR_TURN_002-Q16Atch01 shows that the dollar amount recorded for quality verification audits of VM work in 2020 was approximately $4.9 million. This

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2021WMCE_DR_TURN_002-Q15Supp01 Page 2

overrun is greater than the amount PG&E forecast in total for this suite of work and demonstrates that Quality Verification audits contributed to the overrun for this work.

Please note, the $4.9 million includes a small portion of transmission costs. The QV data is housed on an internal webpage for processing Vegetation Management invoices. This system has limitations on export functionality and does not export to Excel. PG&E is working to convert the attachment to Excel and will remove the transmission amounts from the total recorded costs. PG&E will supplement this response.

Details contained are for the contractor CFVM (California Forestry and Vegetation Management) which was responsible for quality verification audits throughout 2020. No internal PG&E costs are included or being sought. Costs sought only reflect the work of the CFVM contractor to execute the field verification audits.

CFVM has been auditing the Vegetation Management department for over 15 years and have the staff, expertise and knowledge to perform this line of work for QV. They have experienced seasoned arborists available and staff that are familiar with the VM line of business and work performed.

These verification audits document that VM work is in compliance and conformance with regulations, internal processes and procedures. The quality verification teams evaluate and verify completed work for VM’s range of distribution OH programs.

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SUBJECT: VMBA, WMBA


QUESTION 16

Re EVM unit cost overruns discussed on pp. 3-24 - 3-25, driven by the following 5 factors (parts a through e): Increased Volume of Tree Removal; Increased Costs for Wood Management; Increased Costs Due to Higher Time and Equipment Rates; Increased Labor Costs Due to SB 247; Additional Costs for Safety Oversight:

a. Please provide the total 2020 forecasted unit cost for EVM work versus the amount incurred. Please explain and provide all supporting workpapers and calculations.

b. For each of the five factors, separately, please provide the total impact on higher unit costs compared to forecast in 2020 in percentage and dollar terms. Please provide all supporting workpapers, calculations, and assumptions in Excel.

ANSWER 16

See attachment 2021WMCE_DR_TURN_002-Q16Atch01.

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2021WMCE_DR_TURN_002-Q16Atch01

Cost Category 2020 GRC Forecast 2020 Recorded Cost Cost DifferencePercentage Difference Assumptions

Overhang Clearing 147,728$ (147,728)$ -33%Targeted Tree Species Work 186,022$ (186,022)$ -41%Increased Cost due to Higher Volume of Trees Worked -$ Increased Cost due to Higher Time and Equipment Rates 308,751$ 308,751$ 68% (A)Reduced Number of Miles Worked (103,826)$ (103,826)$ -23%Fewer Trees Removed per Mile (20,228)$ (20,228)$ -4%Enhanced VM Maintenance not Performed (32,196)$ (32,196)$ -7%Increased Cost due to SB247 -$ 174,764$ 174,764$ 39%Subtotal Tree Work 333,750$ 327,265$ (6,485)$ Increased Costs for Wood Management 92,733$ 92,733$ 21%Additional Cost for Safety Oversight 21,721$ 21,721$ 5%Reduced Costs for LiDAR and Fuel Reduction 44,356$ 9,671$ (34,685)$ -8%Total 378,106$ 451,390$ 73,284$

Notes:

(A) - Increased Unit Costs due to higher T&E rates: Forecast RecordedMiles 2,922 1,878 Trees per Mile 79 70 Trees 230,838 131,460 Total Cost 333,750,000$ 441,718,502$ Cost per Tree 1,446$ 3,360$

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Appendix 3

Other Documents Relied Upon

Line No.1 Reference2 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 202634 Trims/Prunes 985,649 1,136,496 1,136,974 1,086,439 1,368,327 1,285,132 1,106,650 1,107,267 1,108,729 1,110,847 1,113,736 5 Removals 92,400 127,804 187,357 187,357 191,728 206,493 333,078 332,407 331,117 329,119 326,396 6 Trees Worked 1,078,049 1,264,300 1,324,331 1,273,796 1,560,055 1,491,625 1,551,625 1,546,883 1,537,100 1,522,576 1,503,209 78 Nominal-year SAP$ (thousand) 182,214$ 184,499$ 243,348$ 327,352$ 654,562$ 540,334$ 516,284$ 753,130$ 730,236$ 691,818$ 628,932$ WP 9-6, line 29 Average Unit Cost (Nominal-year SAP$) $169.02 $145.93 $183.75 $256.99 $419.58 $362.25 $332.74 $486.87 $475.07 $454.37 $418.39

101112 Trim Units % 91% 90% 86% 85% 88% 86% 88% 88% 88% 89% 90%13 Removal Units % 9% 10% 14% 15% 12% 14% 12% 12% 12% 11% 10%1415 Notes:16 (1) Starting in 2023 the Routine VM program includes both the trees historically removed as part of Routine VM and the removal of hazard trees as part of the Incremental Routine VM scope of work.1718 Savings $2,357,420.24 $6,900,443.64 $13,199,085.54 $20,256,904.27 $42,713,853.6919 2022 2023 2024 2025 202620 Calculating the forecast number of trees 2022-2026 Routine Regulatory Compliance Trees 1,376,625 1,376,625 1,376,625 1,376,625 1,376,625 21 Reduce Trees Worked as UG Work Occurs (a) - (3,442) (10,325) (20,649) (34,416) 22 Subtotal 1,376,625 1,373,183 1,366,300 1,355,976 1,342,209 2324 Incremental Hazard Tree Removal 175,000 175,000 175,000 175,000 175,000 25 Reduce Trees Worked as UG Work Occurs (a) - (1,400) (4,200) (8,400) (14,000) 26 Subtotal 175,000 173,600 170,800 166,600 161,000 2728 Total 1,551,625 1,546,783 1,537,100 1,522,576 1,503,209 293031 Routine Regulatory Compliance Removal 1,358,898 1,358,898 1,358,898 1,358,898 1,358,898 32 Trim/Prune 192,728 187,886 178,203 163,679 144,312 3334 Trim Units % 88% 88% 88% 89% 90%35 Removal Units % 12% 12% 12% 11% 10%36

(a) PG&E's forecast assumes that it will work fewer trees and remove fewer hazard trees as system hardening underground work progresses

Recorded Forecast

Workpaper Table 9-10Pacific Gas and Electric Company

Exhibit (PG&E-4), Chapter 9, Vegetation ManagementRoutine Vegetation Management Trim and Removal Work

(Nominal Dollars)

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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA,

Plaintiff,

v.

PACIFIC GAS AND ELECTRIC COMPANY,

Defendant.

No. CR 14-00175 WHA ORDER RE MONITOR LETTER

The Monitor has submitted a letter in response to the Court’s request, appended hereto as

Exhibit A, providing an update on its field inspections of PG&E’s vegetation management and

infrastructure inspection operations since last year.

The Monitor has found more exceptions per mile this year than from September to

December of last year. The Monitor believes that one of the reasons for this discrepancy is that

PG&E completed its 2019 EVM work in low-risk portions of its high-fire threat districts in

order to meet its 2019 EVM targets, instead of prioritizing wildfire risk reduction according to

its risk model.

The Monitor also notes that as of August 31, 2020, PG&E failed to conduct any

enhanced, ignition-based climbing inspections of the 967 applicable transmission structures

selected for 2020 inspections in high-fire threat districts. The Monitor believes that this

shortcoming was caused by “human error, lack of oversight, miscommunications, and failure

to appropriately escalate matters,” the same problems that offender PG&E has long had.

Case 3:14-cr-00175-WHA Document 1247 Filed 10/20/20 Page 1 of 2

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By NOVEMBER 3 AT NOON, PG&E shall please explain these shortcomings and any other

points in the Monitor’s letter it wishes to address.

IT IS SO ORDERED.

Dated: October 20, 2020.

WILLIAM ALSUP UNITED STATES DISTRICT JUDGE


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Mark Filip, P.C. To Call Writer Directly:

+1 312 862 2192 [email protected]

300 North LaSalle Chicago, IL 60654

United States

+1 312 862 2000

www.kirkland.com

Facsimile: +1 312 862 2200

Beijing Boston Dallas Hong Kong Houston London Los Angeles Munich New York Palo Alto Paris San Francisco Shanghai Washington, D.C.

October 16, 2020

The Honorable William H. Alsup United States District Court for the Northern District of California 450 Golden Gate Avenue Courtroom 12 - 19th Floor San Francisco, CA 94102

Re: Information Request Regarding Monitor Team Field Inspections

Dear Judge Alsup:

This letter responds to your request for an update on the Monitor team’s field inspections of PG&E’s vegetation management and infrastructure inspection operations since last year.

Vegetation Management

The Monitor team continued conducting vegetation management inspections of PG&E’s Enhanced Vegetation Management (“EVM”) work in August of this year, following the Company’s completion of the majority of its 2020 EVM mileage targets. In sum, based on inspections completed to date (and a smaller sample this year than last, given quarantine restrictions and field conditions), the Monitor team has not seen a meaningful improvement in the quality of work from late 2019 to 2020.

On a per-mile basis, the Monitor team is finding more missed trees (what we refer to as “potential exceptions” to the EVM scope) in 2020 than we did in the later part of 2019. For perspective, from May to July 2019, the Monitor team found 11.4 potential exceptions per mile. After we discussed the underlying deficiencies with PG&E throughout the summer and early fall of 2019, and following revamped training by PG&E, the quality of work improved, and the exception rate dropped to 1.1 potential exceptions per mile from September to December 2019. This year, the Monitor team has found approximately 4.82 potential exceptions per mile, with potential missed hazard trees accounting for roughly half of the exceptions. Therefore, although there were meaningful improvements within 2019, that improvement appears to have, at best, plateaued, and perhaps actual regression has occurred. For the Court’s reference, we have attached a finding from an October 4, 2020 inspection, during which we identified a tree that PG&E was supposed to have removed in mid-August, but twice failed to remove, seemingly because of a series of process breakdowns. The leaves on the tree had singed from contact with the conductor.

Case 3:14-cr-00175-WHA Document 1247-1 Filed 10/20/20 Page 1 of 11

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October 16, 2020 Page 2

Following the Monitor team’s identification of the tree and immediate escalation to PG&E management, PG&E removed the tree within 24 hours.

It is too early to identify with absolute certainty the cause for increased findings this year or whether there is an actual backsliding trend from late 2019. The Monitor team inspections this year are, for the most part, taking place in more vegetation-dense areas than they did last year, which may explain the increased findings. Our sample size so far this year is also smaller than last year. Although we had already intended to inspect fewer miles this year than last, pandemic-related travel restrictions, stay-at-home orders, quarantine requirements, and social-distancing regulations substantially limited our ability to safely send members of our team into the field to inspect remote portions of PG&E’s service territory. Additionally, wildfire-related air quality hazards have forced our inspection teams to remain indoors on many days scheduled for inspections, and the unprecedented scope of wildfires this year has also limited our access to certain inspection locations. Despite these limitations, the Monitor team has analyzed over 1,600 individual conductor line segments and over 10,200 trees with potential to strike electric assets, through inspections of approximately 27.58 miles of EVM work.

One of the reasons the Monitor team believes vegetation density may be playing a role in the increased misses this year stems from field inspection observations and analyses the Monitor team completed in the first quarter of 2020. Specifically, in late 2019 and early 2020, the Monitor team analyzed data collected from approximately 500 miles of line we inspected in 2019, and the more than 1,150 missed trees (including over 300 hazard trees) we identified and reported to PG&E. During those inspections, and particularly towards the later part of 2019 as PG&E was pushing to achieve its year-end EVM targets, Monitor team inspectors were observing fewer and fewer trees—and, at times, no trees at all—on mileage that PG&E had counted towards its 2019 EVM goals. Although we began raising this lack of vegetation density to the Company in December 2019, it prompted us to undertake an in-depth assessment in early 2020 regarding the vegetation density and risk profile of the mileage on which the Company conducted its 2019 EVM work.

In sum, the Monitor team’s findings from our field observations and subsequent data analyses suggested that PG&E completed the majority of its 2019 EVM work in relatively low-risk portions of its high fire-threat districts (“HFTDs”). Put another way, as the Company pushed to meet its 2,455-mile EVM target for 2019, it did not prioritize wildfire risk reduction according to its risk model. PG&E had previously represented that it prioritized 2019 EVM work based on a risk model the Company developed with a third-party consultant, which assigned a risk score for each HFTD circuit. The Company also highlighted that its EVM plan prioritized higher-risk mileage in the multi-year EVM program to achieve the greatest risk reduction sooner rather than later in the plan lifecycle. Despite the fact that the top 100 circuits on the risk model had significantly higher risk scores than the remaining 596 circuits ranked in the model, approximately 59% of PG&E’s completed 2019 EVM mileage was outside of the top 100 circuits. Of course, operational considerations may force some deviations from any risk model or related plan informed by that model, but in this case, the severity of the deviations strongly suggest that the Company prioritized the achievement of EVM mileage targets over the most meaningful wildfire risk reduction.


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Aside from the risk model, our assessment and field observations further revealed that not only were the selected circuits lower risk, but the EVM work completed in 2019 focused on portions of those circuits with fewer trees and that required less tree trimming work under the EVM scope. For example, 92% of mileage that passed EVM work verification (and was therefore counted towards PG&E’s 2019 EVM targets) through November 2019 did not require any EVM tree trimming work. This statistic showed some directional improvement by the end of 2019, dropping to 77%. PG&E continued its directional improvement in 2020 and is conducting EVM work in higher density areas requiring more tree trimming work (preliminary analysis through September 2020 suggests that 57% of the EVM mileage completed in 2020 did not require any EVM tree trimming work, and our field observations suggest PG&E is performing more work in higher tree-density areas). Despite the directional improvement, we believe that the Company needs to do a much better job of prioritizing wildfire risk reduction within mileage targets through its EVM work, while operating pursuant to an effective risk model. The Company has committed to do so and is working on a revised risk model and EVM scope for 2021 EVM work. Preliminary indications (subject to ongoing assessment by the Company) are that the Company is planning to reduce the EVM work scope in 2021, for example, by trimming branches overhanging lines only on selected tree species, instead of all trees, among other reductions, while also planning to achieve its risk reduction targets with fewer resources. The Monitor team is continuing to inquire regarding the Company’s 2021 plans, including whether, if necessary, the Company should devote more resources to meet its Wildfire Mitigation Plan targets, while abiding by its representations that it will do so in a manner that prioritizes overall wildfire risk reduction. Moving forward, the Monitor team will be focusing its vegetation management inspections in areas with greater vegetation density, and we will continue to evaluate the Company’s use of its risk models.

Infrastructure Inspections

The Monitor team is continuing field inspections in 2020 of PG&E’s distribution assets and is including certain transmission assets into our oversight efforts. Our infrastructure inspections began around this time last year, as we commence our work following PG&E’s completion of its own annual inspections of HFTD areas. We received the last of the data necessary to initiate our field checks of PG&E’s work on September 28, 2020. In light of PG&E’s inspection cycle, our plan is to conduct infrastructure field inspections of PG&E’s 2020 inspections program through the second quarter of 2021. In 2019, the Monitor team found issues likely missed by PG&E’s inspectors on approximately 12% of the assets our team inspected, and inspectors failed to collect basic asset information for PG&E’s recordkeeping purposes on approximately one-third of assets inspected. In February 2020, the Monitor team presented specific feedback and findings to the leaders of PG&E’s new System Inspections Team, who incorporated that feedback into PG&E’s 2020 inspections program.

This is the first year of the Monitorship where PG&E has brought PG&E’s entire electric asset inspections program under the leadership of a single Systems Inspections Team at the Company. The Monitor team viewed this centralized accountability as a positive step. However, the Monitor team recently discovered that the Company failed to perform enhanced climbing inspections of selected transmission towers in HFTDs prior to peak fire season this year—we immediately elevated this finding within the Company (senior leadership was unaware). In its initial planning, PG&E had set an internal target (not a Wildfire Mitigation Plan deadline) of


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August 31, 2020 to conduct enhanced, ignition-based climbing inspections of 100% of the 967 applicable transmission structures selected for 2020 inspections in HFTDs. That target would have allowed PG&E to inspect those transmission assets in the highest threat areas and begin any immediate repairs prior to peak fire season. By August 31, 2020, PG&E represented that it had conducted no such inspections (although it had completed less robust ground inspections of the 967 assets, and has since reported making progress on the climbing inspections). Additionally, the Company had conducted approximately 1,000 climbing inspections of transmission towers outside of high threat areas by that time, further underscoring the Company’s shortcomings in executing work in a manner that prioritizes wildfire risk reduction. The failure to timely inspect the HFTD transmission towers pursuant to PG&E’s plan appears to have been caused by human error, lack of oversight, miscommunications, and failure to appropriately escalate matters. The Company has now represented that it plans to complete these inspections by Thanksgiving 2020, and the Monitor team will continue to evaluate the Company’s progress.

Overall, we believe the inspections and related analyses have identified material shortcomings in PG&E’s progress, as compared to its stated goals regarding wildfire risk reduction. This is not to say that the EVM and other wildfire mitigation work PG&E completed in 2019 and 2020 did not result in a meaningful reduction in the wildfire risk profile—they did, and directionally the risk profile is being lowered—but it strongly appears that the Company failed to adhere to its risk models in its work execution and could have done better under its own chosen metrics and approaches. The Monitor team has identified these shortcomings to PG&E leadership and will monitor progress towards meeting past and current PG&E goals. Should the Court have any further questions in the meantime please do not hesitate to reach out.

Sincerely,

Mark Filip


APP3-7

Exhibit – Tree Report


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PG&E Monitor Team Immediate Hazard Reported October 4, 2020 • Segment ID: CIL_AO123-K17_233536

• GPS Coordinates: 37.8359150, -122.2016603

• Nearby Address: 6924 Snake Road, Oakland, CA 94611

• Veg Point ID: VP_AO123-K18_1733229_2020

• HFTD: Tier 3

• Species: Blue Gum / Eucalyptus

• Height: 38

• DBH: 54 (including multiple stems)

• Monitor Team Observations: Leading sprouts of tree observed within one inch of primary conductor, and tree shows evidence of singeing from prior contact with conductor. Tree also located on steep slope with exposed roots.

• PI Comments field in Arc Collector states: “L/O Pl 0907 Uphill Multistem, sent to HN URG 8/12/2020 M8D9 - revisited 8/31/2020, HN not complete, created WI point for removal M8D9”

• Photos of the potential exception are included below.


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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA,

Plaintiff,

v.

PACIFIC GAS AND ELECTRIC COMPANY,

Defendant.

No. CR 14-00175 WHA ORDER TO SHOW CAUSE RE CONDITIONS OF PROBATION

This order to show cause proposes further conditions of probation to require the convicted

utility, in deciding which power lines to de-energize during windstorms, to take into account the

extent to which power lines have or have not been cleared of hazardous trees and limbs as

required by California law and the Offender’s own Wildfire Mitigation Plan (WMP). This

proposal is made to protect the people of California from yet further death and destruction

caused by the Offender’s continuing failure to operate its power grid safely.

* * *

In September 2010, a high-pressure gas transmission pipeline owned and operated by

defendant Pacific Gas and Electric Company exploded in a residential area of San Bruno. The

inferno killed eight, injured 58, and damaged 108 homes, 38 of which were destroyed. The

National Transportation Safety Board (NTSB) immediately investigated and found that PG&E’s


APP3-15

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Integrity Management Program was deficient, ineffective, and a probable cause of the San

Bruno explosion. The investigation further revealed that PG&E lacked complete and accurate

records for its gas transmission pipelines despite receiving notice of recordkeeping deficiencies

through employees, regulatory agencies, and third-party auditors and consultants (PSR ¶¶ 13–

19).

In August 2016, a federal jury convicted PG&E on five felony counts of knowingly and

willfully violating Natural Gas Pipeline Safety Act safety standards and one felony count of

obstructing the NTSB’s investigation arising out of the San Bruno explosion. The felony

judgment that followed imposed the largest fine allowed by law and the longest probation

allowed by law. One of several conditions of probation prohibited the Offender from

committing another federal, state, or local crime. It was also required to notify the probation

office immediately upon learning of any major civil litigation, criminal prosecution, or

administrative proceeding against PG&E, or any investigation or formal inquiry by

governmental authorities regarding the organization. The felony judgment also provided for an

independent monitor to oversee safety aspects of PG&E’s operations (Dkt. No.s 884, 922).

Then came a stunning chapter in California history. Since the commencement of the

Offender’s probation alone, PG&E has ignited 20 or more wildfires in California, killing at least

111 individuals, destroying at least 22,627 structures, and burning half a million acres. Here

follows a summary.

In October 2017, the Wine Country Fires — including the Atlas and Nuns fires — ravaged

more than two hundred thousand acres in Northern California. According to CAL FIRE, PG&E

ignited seventeen of the twenty-one major Wine Country wildfires. The culprit this time was

PG&E’s electricity grid. These seventeen fires alone killed 22 people and destroyed 3,256

structures. Following the Wine Country fires, the Monitor, federal prosecutors, PG&E, and the

Court agreed that the Monitor would evaluate PG&E’s electricity-distribution operations,

including its vegetation-management plan, and equipment-maintenance and inspection

programs. CAL FIRE found that PG&E’s violations of Section 4293 of the California Public

Resources Code specifically had caused at least three of the Wine Country fires.


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All these fires occurred during the wildfire season and during windstorms. During a

windstorm, if a tree or a heavy limb blows onto energized lines, the lines are pushed together,

and because they are uninsulated, a bolt of electricity flashes between the conductors. The

molten metal blazes to the ground where it lands in the dry grass, igniting a wildfire. There is

nothing wrong with the lines being uninsulated, for they almost always have been. Precisely

because they are uninsulated, in 1929, the California Public Utilities Commission (CPUC)

General Order (GO) 95, set forth rules for utilities to ensure that overhead power lines remain

free of tree and limb hazards. Similarly, since 1965, the California Public Resources Code has

separately required utilities like PG&E to police their rights of way and remove trees and limbs

within a specified clearance. During the wildfire season, Section 4293 requires utilities to

maintain a clearance of specified distances “in all directions between all vegetation and all

conductors which are carrying electric current” and to trim or remove hazardous trees or limbs

that may contact the line from the side or fall on the line.

PG&E, however, failed to comply with these safety directives and began to divert funds

from right-of-way maintenance. It used those funds for, among other things, bigger bonuses,

dividends, and political contributions. Inspections of lines and removal of hazardous limbs and

trees got postponed. The backlog of uncompleted work grew and grew. In 2017, we paid the

price in the Wine Country Fires. Windstorms blew trees and limbs onto live PG&E wires and

sparked the conflagrations.

Shortly after the 2017 fires, PG&E, though flush with cash, fled into bankruptcy to

minimize its liability for those wildfires. It also went to the legislature for a relief plan. In 2018,

the California Legislature passed SB 901, which required California’s electrical utilities to create

WMPs, which they must submit annually to the CPUC. WMPs detail utilities’ safety measures

and wildfire prevention efforts. Pursuant to SB 901, PG&E’s WMP would include protocols

and programs for de-energization, vegetation management, and facility inspection and

maintenance. The same bill added factors, including climate conditions, which the CPUC could

use to determine whether and what portion of a utility’s wildfire-related expenses could be

passed along to ratepayers. Soon followed AB 1054, which created an insurance fund for


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utilities, and which required that electrical utilities submit the annual WMPs to the newly-

formed Wildfire Safety Advisory Board for comment. In addition to the annual submission, it

required utilities to comprehensively change their WMPs every three years.

In November 2018, the Camp Fire in Butte County, the deadliest wildfire in California

history, destroyed the town of Paradise, killed 85, and burned 18,793 structures. Again, P&E

caused the fire. One cause was the collapse of an ancient, worn-out C-hook hanging from a

PG&E transmission tower, and another was a tree blowing onto a PG&E distribution line, all as

strong winds swept the region. In all cases, the high winds, known as Diablo Winds, had been

expected, annual events in our autumns.

On January 9, 2019, United States Probation Officer Jennifer Hutchings filed a Form 12

charging that PG&E violated the conditions of its probation by failing to notify her of a $1.5

million settlement entered into with the Butte County District Attorney’s Office, whereby Butte

County had agreed to forgo criminal prosecution in connection with three even earlier wildfires

that CAL FIRE determined had been caused by trees blowing onto PG&E distribution lines.

That same day, another order herein directed the parties to show cause why PG&E’s conditions

of probation should not be modified to, among other things, require PG&E to re-inspect its

electrical grid, remove or trim all trees or branches that might contact PG&E’s equipment during

high-wind events, and to de-energize any part of its electrical grid not yet rated as safe by PG&E

for the wind conditions then prevailing. Hearings followed (Dkt. No.s 960–61).

This led to further probation conditions in April 2019 (Dkt. No. 1040): 1. PG&E must fully comply with all applicable laws concerning vegetation management

and clearance requirements, including Sections 4292 and 4293 of the California Public Resources Code, CPUC General Order 95, and FERC FAC-003-4.

2. PG&E must fully comply with the specific targets and metrics set forth in its wildfire mitigation plan, including with respect to enhanced vegetation management. Compliance with these targets and metrics, however, will not excuse any failure to fully comply with the vegetation laws as required in paragraph 1.

3. The Monitor shall assess PG&E’s wildfire mitigation and wildfire safety work, including through regular, unannounced inspections of PG&E’s vegetation management efforts and equipment inspection, enhancement, and repair efforts. The inspections will include both inspections of segments of power lines where PG&E has


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conducted its enhanced vegetation management efforts pursuant to its wildfire mitigation plan, as well as areas where enhanced vegetation management has yet to occur. The inspections will further include field interviews and questioning of PG&E employees and contractors.

4. PG&E shall maintain traceable, verifiable, accurate, and complete records of its vegetation management efforts. PG&E shall report to the Monitor on the first business day of every month on its vegetation management status and progress, and make available for inspection all related records at the Monitor’s request.

5. PG&E shall ensure that sufficient resources, financial and personnel, including contractors and employees, are allocated to achieve the foregoing. If PG&E cannot find enough contractors, then PG&E must hire and train its own crews to trim and remove trees. To ensure that sufficient financial resources are available for this purpose, PG&E may not issue any dividends until it is in compliance with all applicable vegetation management requirements as set forth above.

At the sentencing hearing on May 7, 2019, PG&E board members and officers were

ordered to visit San Bruno, the site of the gas explosion, and Butte County, the site of the deadly

Camp Fire, to bring home the devastation that PG&E had wrought. PG&E was also required to

create a committee within the Board of Directors to scrutinize PG&E’s fidelity to the WMP and

its conditions of probation. These conditions became the following (Dkt. No.s 1061, 1027,

1071): By no later than July 15, 2019, the PG&E Board of Directors, PG&E’s Chief Executive

Officer and certain other PG&E senior executive leaders, the Monitor, and Probation shall visit Paradise and San Bruno to gain a firsthand understanding of the harm inflicted on those communities and meet with victims and other stakeholders, such as fire-fighting personnel and/or city officials.

A committee of the PG&E Board of Directors shall assume responsibility for tracking progress against PG&E’s Wildfire Safety Improvement Plan, as approved by the California Public Utilities Commission, and the new terms of probation imposed on April 3 regarding wildfire safety. The committee is to report in writing to the Board at least quarterly, and also present orally to the Board at least quarterly, PG&E’s progress in meeting the terms of the approved Wildfire Safety Improvement Plan and the April 3 terms of probation and, to the extent there are shortfalls, how PG&E will address the shortfalls.

In June 2019, the Court, the Monitor, PG&E’s board of directors, its officers, and

Probation Officer Hutchings all went to Paradise, Ground Zero of the Camp Fire. They learned

from first responders and survivors of the Camp Fire about the devastation that wrecked the


APP3-19

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county and killed so many, all because of PG&E’s safety failures. The same group visited the

San Bruno pipeline explosion site in July to see and hear the full story of that crime.

In Butte County, PG&E would eventually admit responsibility for 84 deaths in the Camp

Fire and would plead guilty in June 2020. See THE NEW YORK TIMES, “PG&E Pleads

Guilty to 84 Counts of Manslaughter in Camp Fire” (June 16, 2020). It also would agree to pay

$13.5 billion to the victim’s compensation fund, a $4.5 million dollar fine, and $500,000 to

cover the costs of the prosecution.

This Court urged, but ultimately did not require, PG&E to temporarily de-energize any

power line unsafe to operate during dry-season windstorms. PG&E protested the idea at the

time and resisted any proposed order to engage in such temporary de-energizations. During the

2019 fire season, however, PG&E voluntarily implemented eight power shutoffs, which came to

be known as Public Safety Power Shutoffs (PSPSs). No major wildfire, in fact, came from a

PG&E distribution line failure in 2019. This represented an important safety development.

Most significantly, during the entire wildfire season in 2019, no lives were lost from wildfires

started by PG&E. This stood in stark contrast to preceding years. Troublesome and aggravating

as those power shutoffs certainly were, that paled in comparison to the death and destruction

caused in the preceding years. Photos of downed trees draped over de-energized distribution

lines in the wake of the windstorms demonstrate what might have occurred had the power been

left on and the massive extent to which PG&E has failed to maintain the required clearances.

During 2019, PG&E conducted eight PSPSs. PG&E found that 334 trees or limbs fell on

distribution lines during just four PSPSs in October. Of these fallen trees, PG&E estimated that

234 would have caused arcing (in which electricity would have flown to the closest conducting

surface, such as the dry, grass-covered earth). Here are four photographs from the October 26 or

29 PSPSs illustrating the point (Dkt. No.s 1110, 1119, 1132):


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A blown-over tree and broken conductors in Sonoma County.

A tree blown onto conductors in Alameda County.


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A tree blown onto conductors in unincorporated Napa County.

A tree blown onto conductors in unincorporated Lake County.


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Public Safety Power Shutoff Oct. 26–Nov. 1, 2019 Report to the CPUC, Appx. C, Fig.s 1, 5, 6,

7.

Although no distribution line ignited a wildfire in 2019, a PG&E transmission line did fail

and cause a major wildfire, the Kincade Fire in Sonoma County. A transmission tower at the

intersection of Kincade and Burned Mountain Roads saw a jumper cable break loose during a

windstorm, contact the metal tower, and short out, tossing electrical sparks onto the dry wind-

blown grass. It burned through over 77 thousand acres and destroyed 374 structures, but,

mercifully, killed no one. CAL FIRE blamed PG&E. See SAN JOSE MERCURY NEWS,

“PG&E Power Lines Caused Kincade Fire in Sonoma County” (July 16, 2020).

To patrol and clear its right of ways, PG&E has in this century outsourced all

responsibility, both as to inspections to identify hazardous trees and limbs and as to cutting

them. Since the Wine Country Fires, PG&E has ramped up its outsourcing. As of April 2020, it

had under contract over 1,000 “pre-inspectors” to flag trees that violated clearance requirements

and roughly 5,000 tree-trimmers to follow behind to remove them. This clearing work,

however, has been sloppy and missed dangerous conditions entirely. The Court asked the

Monitor to perform unannounced spot checks on outsourced work and the Monitor reported

numerous shortfalls (and continues to do so). When called to account, PG&E routinely shrugs

and says it didn’t know of the substandard work done by the outsourcees.

The problem was that PG&E needed at least some inspectors on its own management team

to oversee the quality (or not) of the outsourced work. Put differently, PG&E needed its own

inspectors to do what the Monitor had been doing. This led the Court to impose, in April 2020,

additional terms of probation regarding inspections and to require PG&E to hire and train its

own inspectors so as to better manage quality control over its contractors. They were as follows

(Dkt. No. 1243): 8. Vegetation Condition: PG&E shall, by September 1, 2020, staff an in-house vegetation

management inspection manager to oversee a number of workforce resources who will provide in-field oversight of all stages of the vegetation management process, including the enhanced vegetation management program work, to be deployed throughout PG&E’s territory, including High Fire-Threat Districts (HFTDs). By the end of September 2020, PG&E will extend offers to 10 in-house field supervisors and/or


APP3-23

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inspectors, an additional 10 inspectors by the end of November, and the remaining approximately 10 inspectors by the end of January 2021. The inspectors shall conduct in-field oversight of PG&E contractors while the work is being performed, verifying and correcting any deviation from applicable scopes of work pursuant to PG&E policies and legal requirements. The inspectors shall also oversee pre-inspectors to help ensure they are clearly marking and designating trees for trimming and removal, and that tree-trimming contractors are appropriately performing their duties. Deviations from applicable scopes of work shall also be accurately recorded and reported to PG&E and the Monitor team to be used for, among other things, ongoing training of PG&E’s contract workforce.

9. Asset Age Condition: For certain critical transmission tower components in High Fire-

Threat Districts, the failure of which may result in an ignition, PG&E shall conduct a reasonable search and, where available, record the age and date of installation of those components. For all other such critical transmission components and where asset-age records are not reasonably available, PG&E shall make conservative assumptions of such ages and dates of installation. PG&E shall also implement a program to determine the expected useful life of critical components factoring in field conditions and incorporate that information into its risk-based asset management programs. PG&E shall begin this effort (or supplement any existing or planned initiatives) immediately and provide monthly progress reports to the Monitor team.

10. Transmission Inspection Program Condition: PG&E shall, by the end of 2020,

supplement its transmission-asset inspections program to include the following measures: (1) hire a crew of in-house and/or contract inspectors, independent from inspectors conducting transmission inspections, to oversee in the field transmission inspections while they are being conducted; (2) going forward, and subject to CAISO clearances and/or other external dependencies, revise the material loss threshold for the replacement of cold-end hardware (including C-hooks and hanger plates) in HFTDs to create a 90-day replacement requirement for such hardware with an observed material loss approaching 50%; and (3) make the prior two years of inspection reports available to transmission post-inspection review teams starting in 2021, and one year of inspection reports available in 2020.

These conditions were worked out by the Monitor and eventually stipulated to by the

Offender.

Unlike 2019, when no PG&E distribution lines caused any major wildfires, thanks to the

PSPSs, 2020 saw a return to distribution-line disaster. On September 27, 2020, during a

windstorm, a fire ignited in the area of Zogg Mine Road and Jenny Bird Lane in Shasta County

(Zogg Fire). The Zogg Fire killed four: Alaina Michelle Rowe and her eight-year-old daughter

died when flames overtook their pickup truck, Karin King also died trying to escape in her

vehicle, and Kevin Vossen succumbed to burns. It also destroyed 204 structures.


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As of this moment, CAL FIRE has not blamed the Zogg Fire on PG&E, but there are clear

signs that PG&E bears responsibility. On October 9, PG&E disclosed that CAL FIRE had taken

possession of PG&E equipment as part of an ongoing investigation into the origins of the Zogg

Fire. CAL FIRE also seized portions of a gray pine in connection with its investigation. The

gray pine had been looming over a section of distribution line (the area of interest) along

PG&E’s Girvan Circuit. On October 12, an order herein requested that PG&E explain its role in

the ignition of the Zogg Fire, including whether inspections of the Girvan Circuit had previously

identified trees for trimming or removal and the status of that work.

The gray pine looming over the Girvan Circuit prior to the Zogg Fire (Dkt. No. 1250-4).

According to PG&E’s response, when the Zogg Fire erupted during the windstorm, a

PG&E SmartMeter and a line recloser serving the area of interest reported drops in voltage and

other activity from approximately 2:40 p.m. to 3:06 p.m., when a line recloser deenergized that

portion of the Girvan Circuit. NOAA’s geostationary weather satellite detected a fire in the area

at 2:46 p.m. PG&E reports that CAL FIRE confiscated, among other things, several shattered


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and at least one burned piece of distribution-line infrastructure from the area of interest (Dkt.

No. 1250 at 4–5, 7).

Although other distribution lines in Shasta County were de-energized during the

windstorm, PG&E had left the Girvan Line fully energized.

PG&E admits that it had failed to perform work on trees that had been designated for

removal or trimming in the area of interest. Specifically, in August 2018, a subcontractor

identified “for removal two Gray Pine trees that have a location consistent with the location of

the Gray Pine from which CAL FIRE appears to have collected sections after the Zogg Fire.”

PG&E acknowledges that these gray pines, along with others identified, “may not have been

worked despite being identified for work by the” California Forestry and Vegetation

Management Quality Control “inspector.” PG&E also admits that the area of interest had not

received a separate Catastrophic Event Memorandum Account (CEMA) patrol in 2019, as was

required. PG&E’s CEMA patrols involve visual inspections for dead and dying trees in the

highest-risk portions of its distribution lines. They supplement PG&E’s standard vegetation

management inspections. In April 2019, a PG&E database contractor (yet another outsource)

logged into the inspection scheduling system and changed the scheduled start date for the

CEMA patrol, which had been scheduled to occur in November 2019. The individual reset the

inspection for February 2019, a date that had already passed. Consequently, the CEMA patrol

of the area of interest ultimately did not take place (Dkt. No. 1265 at 24, 31, 32).

Shasta and Tehama Counties have recently sued PG&E in state court, and the Shasta

County District Attorney’s office is investigating criminal charges against the utility. See SAN

FRANCISCO CHRONICLE, “Shasta, Tehama Counties Sue PG&E, Alleging Negligence Led

to Zogg Fire” (Dec. 10, 2020); see also REDDING RECORD SEARCHLIGHT, “More than 150

in Shasta County Join to Sue PG&E over Zogg Fire” (Dec. 16, 2020). Additionally, PG&E

reported to the Securities and Exchange Commission in mid-December 2020 that it expects to be

liable for $275 million or more in damages to victims of the fire (Dkt. No. 1270-1).

Since some of the distribution lines in Shasta County were shut off during that windstorm

but the Girvan Line was somehow left on, the Court asked PG&E to explain its PSPS decision-


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making process. The responses led to more follow-up questions. The Court was surprised to

learn PG&E did not and does not consider the extent to which distribution lines have been

cleared of hazardous trees and limbs in designating lines for a PSPS (Dkt. No.s 1265, 1271).

The Zogg Fire illustrates this point. Shortly before September 27, as the northern counties

braced for the windstorm, PG&E initiated a PSPS analysis and ultimately de-energized several

circuits in that region, beginning on the 27th, in anticipation of high winds and dangerous

conditions. PG&E proceeded in two steps. Initially, variables including weather, fuel humidity,

terrain, and forecasted wind speeds (among others) fed an algorithm, which rated regions by risk

of catastrophic wildfire. In other words, the algorithm was supposed to predict the areas facing

an unacceptable risk of catastrophic wildfire and nominate those areas (and those areas alone)

for de-energizing. Significantly, however, its inputs did not (and still do not) consider

compliance (or not) with clearance mandates. As a result, the algorithm ignored the main

problem and ignored the entire extent to which any line had or had not been cleared.

Next, PG&E’s meteorology team and other decision makers examined each of those

nominated regions and decided whether to de-energize the overhead electrical wires that traverse

them. As part of this second-stage analysis, once a line was designated for a PSPS, PG&E went

out to try to find and remove hazardous trees in order to possibly “adequately reduce the risk of

catastrophic wildfire” and subtract the line from the PSPS. (Of course, very little time remained

to do this.) But, to repeat, in nominating the lines for a PSPS in the first place, PG&E ignored

(and still ignores) the extent of risk from hazardous trees and limbs. This meant (and still

means) that a distribution line beset by hazardous trees and limbs would not be nominated

unless, by luck, the other criteria happened to indicate sufficient risk (Dkt. No.s 1265, 1271,

1250-5 at 16).

It is most confounding that PG&E, in deciding which distribution lines to de-energize in a

PSPS, ignored (and still ignores) the number-one cause of wildfires ignited by PG&E:

hazardous trees and limbs that should have, by law, been removed but which still loom as threats

in windstorms. There can be no debate about the dangers of dead, dying, and untrimmed trees

near live distribution lines. By PG&E’s own admission,


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[v]egetation-caused ignitions are one of the largest drivers of utility-caused wildfires, and the largest driver in HFTD areas. We estimate that 70 percent of the time, if identified vegetation is not worked, it can cause a power-line failure under high fire threat weather conditions.

Pacific Gas and Electric Company Quarterly Report on 2020 Wildfire Mitigation Plan for May

to July 2020 (Sept. 9, 2020), at 11.

So, here we are again, concerned with the most serious life and death question arising out

of PG&E’s continuing safety violations of California law in its failure to remove dangerous trees

and limbs from its distribution lines. This problem is often referred to as "vegetation

management.” But that term vastly understates and marginalizes its true severity. It’s not a

matter of landscaping or gardening. It’s a matter of life and death.

PG&E’s recent responses, and a December 2020 letter from the Monitor, illuminate gaps

in PG&E’s compliance with California law, recordkeeping, and compliance with various terms

of its probation. (The Monitor letter is appended hereto as Exhibit 1.)

First, PG&E continues to be in violation of Section 4293 because it has failed to remove

all trees and limbs within the required clearances. PG&E admits this (Dec. Monitor Ltr. at 8,

10).

Second, in 2020, PG&E continued to allow trees to threaten distribution lines in violation

of California law. PG&E found 157 “Level 1” trees (posing imminent threats to distribution

lines), between January and April 2020. PG&E violated GO 95 by failing to ameliorate these

hazardous trees within 24 hours. Then there are the trees that PG&’s work failed to address. On

lines certified “compliant,” PG&E’s internal reviews found 432 trees that failed. The Monitor’s

independent, and smaller-scope review found an additional 153 dangerous tree conditions (id. at

8, 10, Exh. G).

Within California’s HFTDs, as well, the Monitor found that PG&E’s work regularly

“missed trees.” HFTDs denote areas of the power grid that carry a heightened risk of severe

wildfires. The HFTDs include three separate risk tiers, in order from least to most dangerous:

Tier 1 refers to the “high hazard” areas on the U.S. Forest Service-CAL FIRE tree-mortality


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map, Tier 2 refers to areas with an “elevated risk” of utility-caused wildfires, and Tier 3 refers to

areas with an “extreme risk” of utility-caused wildfires. In its WMP, PG&E has adopted more

stringent internal standards for trimming and removing trees within the HFTDs. These

standards are referred to as Enhanced Vegetation Management (EVM) “scope.” The Monitor

found more exceptions to the EVM scope per mile than it had between September and

December of 2019. Alarmingly, these exceptions included more trees overhanging distribution

lines and trees that posed a strike risk, per mile, than the Monitor found from September to

December 2019. The Monitor did report that, in 2020, PG&E completed over 1,800 miles of

EVM inspections and tree work in HFTDs and that “non-conformance with the EVM scope is

more the exception than the norm.” Yet PG&E’s work continued to overlook potentially deadly

trees (id. at 2–3, 5–6).

Third, there “continue to be gaps in PG&E’s recordkeeping” of inspections and vegetation

work, in violation of PG&E’s WMP and fourth condition of probation. While acknowledging

improvements since 2019, the Monitor still found troubling errors. For example, within

PG&E’s records, “approximately 8,200 trees” displayed risk “scores indicating” they should be

removed, but were nonetheless “marked in the internal system as not requiring tree work.” The

Monitor also reports, “PG&E’s maps for EVM work are still not accurate and complete.” Some

maps omitted entire segments of circuits. In one case, the Monitor even found a radial clearance

violation on the real-life segment of the circuit that was missing from the map; but for the

Monitor’s inspection, this radial clearance violation would remain today (id. at 11–13 (emphasis

added)).

Fourth, PG&E has reported to the CPUC that it will fall short of fulfilling its WMP in

2020. PG&E’s WMP incorporated multiple goals, of which PG&E anticipates it will fail to

meet three. One deals with post-PSPS power restoration to customers, but two involve

improvements to its SmartMeters to better detect service transformer failures and voltage drops

that indicate downed distribution wires. Both of the latter aim to help prevent wildfires, but

PG&E is not projected to meet those WMP commitments (id. at 6–7).


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Fifth, the Monitor emphasized that in 2019 and 2020, PG&E failed to use risk models as

“the predominant input . . . in PG&E’s [EVM] work planning and execution for 2019 and 2020.”

This choice by PG&E defies belief. The Monitor called on PG&E “to give greater weight to

working the riskiest areas first” with respect to hazardous trees (a goal, it acknowledges, that

PG&E seems poised to improve upon in 2021) (id. at 2).

This order recognizes that PSPS events, necessary because PG&E has failed to clear

hazardous trees and limbs, cause huge disruptions for the public. Businesses suffer and

residents who use medical devices go without electricity. Still, in October of last year, PG&E’s

then-CEO and President Bill Johnson stated that PSPS events could continue for up to 10 years,

since it will take that long for the Offender to bring its lines into compliance and thus eliminate the

need for PSPS events during windstorms. See KQED, “The PG&E Public Safety Power Shutoffs

Could Continue for 10 Years, Says CEO” (Oct. 18, 2019). The PSPS is the lesser evil and will

remain essential until PG&E finally comes into full compliance with respect to removing

hazardous trees and limbs and honoring the required clearances.

PG&E is therefore ordered to show cause why the below proposed conditions of probation

should not be added as conditions reasonably necessary to protect the public from further death

and destruction and to help rehabilitate the Offender (18 U.S.C. §§ 3553(a)(1), (a)(2)): 11. In determining which distribution lines in Tier 2 or Tier 3 to de-energize during a

PSPS, PG&E must take into account all information in its possession and in the possession of its contractors and subcontractors concerning the extent to which trees and/or limbs bordering those lines remain in violation of Public Resources Code Section 4293, GO 95, FERC FAC-003-4, and/or its own wildfire mitigation plan.

12. To the extent that such information shows that such trees and limbs present a safety hazard in the event of a windstorm, PG&E must make a specific determination with respect to that distribution line and it must de-energize it unless PG&E finds in writing that there are specific reasons to believe that no safety issue exists.

PG&E may continue with its two-step process so long as it also follows the new conditions

herein.

A few weeks ago, a prior question to PG&E raised the general proposal in this order and

PG&E replied. This order now poses a specific version of that question. Rather than treat the


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earlier answer as PG&E’s response, this order gives the Offender a fresh opportunity to show

cause.

PG&E is ordered to show cause why the above further conditions of probation should not

be added. Its response shall be due JANUARY 20, 2021, AT NOON. The government shall please

submit its brief by JANUARY 25, 2021, AT NOON. A hearing shall be held on FEBRUARY 3, 2021,

AT 8 A.M. by Zoom (if not in person).

IT IS SO ORDERED.

Dated: December 29, 2020.

WILLIAM ALSUP UNITED STATES DISTRICT JUDGE


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Mark Fil ip, P.C. To Call Writer Directly:

+1 312 862 2192mark.fi l [email protected]

300 North LaSalle Chicago, IL 60654

United States

+1 312 862 2000

www.kirkland.com

Facsimile: +1 312 862 2200

Beijing Boston Dallas Hong Kong Houston London Los Angeles Munich New York Palo Alto Paris San Francisco Shanghai Washington, D.C.

December 16, 2020

The Honorable William H. Alsup United States District Court for the Northern District of California 450 Golden Gate Avenue Courtroom 12 - 19th Floor San Francisco, CA 94102

Re: Court Request for Monitor Comments on PG&E Vegetation Management Matters

Dear Judge Alsup:

This letter responds to the Court’s request (Dkt. 1269) for the Monitor team (i) to provide the Court information regarding PG&E’s compliance with several conditions of probation related to the Company’s vegetation management (“VM”) program, and (ii) to comment on PG&E’s November 3, 2020 response (Dkt. 1258) to the Monitor’s October 16, 2020 letter to the Court (Dkt. 1247, Ex. A; the “October 16 Letter”) regarding the Monitor team’s field inspections and related observations. We begin below by briefly commenting on PG&E’s response to the October 16 Letter, and then by responding to the Court’s specific inquiries regarding PG&E’s compliance with various VM-related probation conditions.

Comments Regarding PG&E’s November 3, 2020 Response

PG&E’s November 3 response to the October 16 Letter highlighted, among other things, that: (i) the Company did not intentionally target low-risk line miles for enhanced vegetation management (“EVM”) work in 2019; (ii) risk rankings of high fire-threat circuits were just one of many inputs in PG&E’s EVM work planning in 2019; (iii) 40% of EVM mileage—as well as the abatement of significant vegetation in 2019—was completed in the top 100 risk-ranked circuits; and (iv) work planning for 2021 is on a different trajectory from 2019 and 2020 under the leadership of PG&E’s Chief Risk Officer, with a plan to increase the percentage of work targeting the riskiest areas. The Monitor team does not dispute these representations and does not believe anything noted in PG&E’s response changes or affects the assessments in the October 16 Letter. Additionally, the Monitor team respectfully notes that PG&E did not challenge the accuracy of any of the information presented in the October 16 Letter.

PG&E’s wildfire mitigation efforts are meant to reduce wildfire risk. PG&E’s EVM program is one of those efforts. In 2018, PG&E undertook the effort and expended the resources to identify and rank the highest-risk circuits in its service territory to plan and prioritize EVM work

Case 3:14-cr-00175-WHA Document 1277-1 Filed 12/29/20 Page 1 of 16WildfireMitigationPlans_DR_CalAdvocates_035-Q12-Atch03

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December 16, 2020 Page 2

in 2019. Commendably, under its chosen risk models, PG&E represented that it would execute on its multi-year EVM plan by addressing the higher-risk work first to reduce more risk sooner rather than later. However, as PG&E noted in its response, the Company ultimately used its risk models as only one of many inputs (and based on the Monitor team’s assessment, not the predominant input in light of the assessments detailed in our October 16 Letter) in PG&E’s work planning and execution for 2019 and 2020. In sum, PG&E missed opportunities in 2019 and 2020 to do what it must in 2021—in making operational and planning decisions, give greater weight to working the riskiest areas first and do so in a rigorous, consistent, methodical, and measurable way.

To its credit, PG&E has recently made significant progress down this path. Under the leadership of its new Chief Risk Officer, PG&E has brought rigor and discipline to the prioritization of wildfire risk reduction in its wildfire mitigation work planning for 2021. There is now a direct link between the work planned to be done and the risk model’s ranking of high-risk circuits. PG&E described some of these measures in its response to the October 16 Letter, including a weekly meeting chaired by the Chief Risk Officer in which the Company’s leaders in various areas responsible for wildfire mitigation efforts convene to discuss risk models, work planning, and risk prioritization for 2021. The Monitor team observes these meetings and views this deliberative process for the selection of wildfire mitigation work—where risk is the predominant factor, not a factor among many—as a significant, positive development over the work planning and execution in 2019 and 2020. In fact, planning thus far has revolved around the concept that 80% of the wildfire mitigation work planned for 2021 will occur in the applicable top 20% of riskiest areas and is focused on employing the greatest practical risk reduction measures within those areas.1 We will continue to observe, evaluate, and assess PG&E’s planning and execution of work in 2021, including whether PG&E adheres to its stated plans and representations. The Monitor team is encouraged by the 2021 planning process thus far and the leadership of PG&E’s Chief Risk Officer.

Vegetation Management Compliance Matters

The Court requested that the Monitor team comment on PG&E’s compliance with several conditions of probation relevant to VM, including: (i) certain VM regulations; (ii) PG&E’s EVM commitments in its Wildfire Mitigation Plan (“WMP”); (iii) the requirement that PG&E maintain traceable, verifiable, accurate, and complete records of its VM work; and (iv) the requirement that PG&E onboard inspectors to verify VM work in the field. Further information regarding these matters is provided below. While much of the information relayed below identifies instances where PG&E has not complied with its EVM scope, the vast majority of situations we encounter—and trees we evaluate in the field—through our inspections are, in fact, in compliance. In sum,

1 Of course, PG&E also must comply with applicable regulations, including local and environmental rules, and consider the health and safety of its workers and operational realities like wildfires. The point is that there is a material difference between making risk reduction the top priority criterion, and using risk reduction as only one of several considerations to prioritize work. To its credit, PG&E now appears to be employing the former prioritization method and not the latter.


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non-conformance with the EVM scope is more the exception than the norm, but our inspections regularly identify missed trees.

1. Scope of the Monitor Team’s Review

Consistent with Modified Probation Condition #3,2 the Monitor team’s VM field inspections are focused on assessing the Company’s compliance with its EVM scope and related procedures, while using the results of those inspections to provide feedback to PG&E for continuous improvement. Those inspections, as well as information provided to the Monitor team by PG&E, form the basis of much of the reporting herein related to compliance with the EVM scope and applicable VM legal requirements. The EVM scope—as reflected in the WMP and as described in greater detail below—includes hazard tree mitigation, maintaining minimum radial clearances, and mitigation of overhanging vegetation (among other mitigation activities). Because the EVM program builds upon and exceeds regulatory requirements, some of the EVM scope violations identified by the Monitor team (referred to as “potential exceptions”) may or may not also constitute potential non-conformances with regulatory requirements. For example, failure to comply with EVM requirements with respect to hazard tree identification and abatement may also violate Rule 35 of General Order 95 and Section 4293 of the California Public Resources Code. However, failure to remove a healthy branch overhanging a line by 30 feet would violate PG&E’s EVM scope, but would likely not violate these regulatory provisions. Similarly, vegetation encroaching a two-foot radial zone around a conductor would likely violate both applicable regulations and the EVM scope, but a tree that encroaches within eight feet after being trimmed would only violate the latter.

2. PG&E’s WMP Commitments for EVM and Select Other Programs (Modified Probation Condition #2)

In its 2020 WMP, PG&E committed to completing 1,800 miles of EVM in HFTDs, following the 2,498 EVM miles the Company completed in 2019 (based on a target of 2,455 miles). (PG&E 2020 WMP Report, Updated Mar. 17, 2020 (“March 2020 WMP”), at 5-196.)3 While PG&E has met its 1,800-mile EVM commitment for 2020, the Monitor team’s field inspections identified multiple instances of potential non-conformance with the EVM scope.

2 “Modified Probation Conditions” refer to the additional probation conditions that the Court imposed in its April 3, 2019 Order (Dkt. No. 1040), and that the Court supplemented in its May 14, 2019 Order (Dkt. No. 1071) and its August 7, 2020 Order (Dkt. No. 1243), reflecting a total of eight Modified Probation Conditions that are numbered as set forth in the August 7, 2020 Order.

3 Available at https://www.pge.com/pge_global/common/pdfs/safety/emergency-preparedness/natural-disaster/wildfires/wildfire-mitigation-plan/2020-Wildfire-Safety-Plan-Redline.pdf.


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https://www.pge.com/pge_global/common/pdfs/safety/emergency-preparedness/natural-disaster/wildfires/wildfire-mitigation-plan/2020-Wildfire-Safety-Plan-Redline.pdf

https://www.pge.com/pge_global/common/pdfs/safety/emergency-preparedness/natural-disaster/wildfires/wildfire-mitigation-plan/2020-Wildfire-Safety-Plan-Redline.pdf


a. EVM Scope

PG&E’s EVM scope is intended to expand upon its routine VM program by conducting additional vegetation clearance and mitigation work on overhead distribution lines in HFTDs. (Id. at 5-176.) There are three key aspects of the EVM scope:

• Radial Clearances . PG&E seeks to “[e]xceed[] the 4-foot minimum clearance requirement by ensuring vegetation is trimmed to the CPUC recommended 12-foot clearance at time of trim to maintain compliance year-round, and in some cases, trimming beyond 12 feet depending on tree growth rates, among other factors. Trimming to the CPUC recommended 12-foot clearance ensures compliance with GO 95, Rule 35 year-round.” (Id.)

• Overhang Trimming. PG&E seeks to “[r]emov[e] overhanging branches and limbs four feet out from the lines and up to the sky for particular trees around electric power lines to further reduce the possibility of wildfire ignitions and/or downed wires and outages due to vegetation-conductor contact.” (Id.)

• Assessing Trees with the Potential to Strike (commonly referred to as “hazard” trees). PG&E seeks to “[e]valuat[e] all trees tall enough to strike electrical lines or equipment and, based on that assessment, trim[] or remov[e] trees that pose a potential safety risk, including dead and dying trees.” (Id. at 5-177.)

b. Observations Regarding PG&E’s Compliance

i. The Monitor Team’s Analysis

PG&E’s records reflect that, as of late November, the Company has completed 1,843 EVM miles in 2020, thereby exceeding its WMP commitment of 1,800 miles.

As we discussed in our October 16 Letter, the Monitor team’s inspections have identified EVM quality-of-work issues since we first began field inspections in May 2019. Specifically, from May to July 2019, we identified 11.4 potential exceptions to the EVM scope per mile. 4 Following the Monitor team’s feedback to PG&E in July 2019, we saw an improvement in the quality of work, and the potential exception rate dropped to 1.1 potential exceptions per mile from

4 The Monitor team appreciates that PG&E may not accept that all potential exceptions the Monitor team identifies are exceptions in the Company’s view (this is one reason why the Monitor team refers to its findings as “potential” exceptions). The Monitor team understands that, while radial clearance and overhang exceptions are more straightforward and objective, identification of “hazard” trees (for example, trees that are dead, rotten, decayed, diseased, showing signs thereof and posing a risk of striking the line) can involve a degree of subjectivity over which reasonable minds may differ. The Monitor team adopts a conservative approach in its assessment of potential hazards, erring on the side of safety, and also to highlight to the Company defects with trees that went unrecorded by its inspectors—valuable information for a Company to know regarding the status of trees with line-strike potential. Additionally, although unlikely in most circumstances, the possibility exists that the condition identified by the Monitor team developed between the time PG&E inspected the tree and the Monitor team inspected the tree.


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September to December 2019. In 2020, based on our inspections of approximately 42 miles, we have identified 3.5 potential exceptions per mile (149 potential exceptions in total).5

The Monitor team’s inspections have included circuit segments in all phases of PG&E’s EVM work cycle, including segments that have been pre-inspected, tree worked, and work verified. The Monitor team has targeted its inspections on circuit segments that have passed work verification—based on PG&E’s processes, a circuit segment can be “counted” towards its WMP mileage target only after it has passed work verification. Although our inspections identify potential non-conformances with the EVM scope of work through all stages of the EVM process (pre-inspection, tree work, and work verification) for purposes of providing continuous and holistic feedback to the Company, we focus our reporting here on EVM non-conformances that remain after PG&E has verified work as complete. The Monitor team would consider these findings—issues missed by PG&E through all stages of EVM and that remained unaddressed and undetected even after the work was verified as complying with the EVM scope—to be violations of the EVM scope to which PG&E committed in its WMP.

Approximately 76% of the miles we have inspected thus far in 2020 passed work verification (that is, 32.09 miles passed work verification out of a total of 42.03 miles we inspected under the EVM scope). On the circuit segments that comprise those 32.09 work-verified miles, we found 2.4 potential exceptions per mile, for a total of 78 potential exceptions on work-verified miles related to hazard trees, overhangs, or radial clearances. For context, our analysis also reflects that 98.7% of the trees we reviewed on circuit segments that had passed work verification complied with the EVM scope (5,981 trees out of 6,059 total trees). Additionally, the Monitor team notes that the rate of 2.4 potential exceptions per work-verified mile is significantly lower than the 7.1 potential exceptions per mile that we observed for circuit segments that had not yet passed work verification. While the Monitor team respectfully suggests that there is still room for improvement, the lower potential exception rate for miles that passed work verification suggests that the Company’s work verification process is having a positive impact by identifying missed trees and improving adherence to the EVM scope.

With respect to hazard trees, we observed 0.30 potential hazard exceptions per work-verified mile from September to December 2019 (for a total of 40 potential hazard exceptions on work-verified miles), which accounted for 65% of the total exceptions observed from September to December 2019 on work-verified miles. In 2020, we have identified 1.50 potential hazard exceptions per work-verified mile (for a total of 48 potential hazard exceptions on work-verified miles), which accounts for 62% of the total potential exceptions we have identified on work-verified miles. For the Court’s reference, attached as Exhibit A are five examples of trees (out of the 48 total potential hazard exceptions we identified) that, in our view, would violate the EVM scope, because the segments on which we identified them were work verified despite not complying with the EVM scope. The examples provided to the Court as part of Exhibit A are also

5 As we noted in the October 16 Letter, we cannot state definitively that the quality of PG&E’s EVM work is on a downward trend. Among other things, our 2020 inspections have taken place in more vegetation-dense areas in 2020 than in 2019. Additionally, due to a variety of challenges stemming from the pandemic and the wildfire season, we have inspected fewer miles in 2020 than in 2019, and thus our sample may be less representative.


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examples where PG&E agrees with the Monitor team’s assessment that the identified issue failed to meet PG&E’s EVM scope as of the date of the Monitor team’s inspection.

With respect to limbs overhanging the lines, the Monitor team observed 0.12 potential overhang exceptions per work-verified mile from September to December 2019, for a total of 16 potential overhang exceptions on work-verified miles. In 2020, we have identified 0.37 potential overhang exceptions per work-verified mile, for a total of 12 potential overhang exceptions on work-verified miles. For the Court’s reference, attached as Exhibit B are five examples of trees (out of the 12 total potential overhang exceptions we identified) that, in our view, would violate the EVM scope, because the segments on which we identified them were work verified despite not complying with the EVM scope. The examples provided to the Court as part of Exhibit B are also examples where PG&E agrees with the Monitor team’s assessment that the identified issue failed to meet PG&E’s EVM scope as of the date of the Monitor team’s inspection.

With respect to radial clearances, the Monitor team observed 0.05 potential radial clearance exceptions per work-verified mile from September to December 2019, for a total of six potential radial clearance exceptions on work-verified miles. In 2020, we have identified 0.56 potential radial clearance exceptions per work-verified mile, for a total of 18 potential radial clearance exceptions on work-verified miles. For the Court’s reference, attached as Exhibit C are five examples of trees (out of the 18 total potential radial clearance exceptions we identified) that, in our view, would violate the EVM scope, because the segments on which we identified them were work verified despite not complying with the EVM scope. The examples provided to the Court as part of Exhibit C are also examples where PG&E agrees with the Monitor team’s assessment that the identified issue failed to meet PG&E’s EVM scope as of the date of the Monitor team’s inspection (in two instances, PG&E agreed with the Monitor team’s finding but believed that the radial clearance issue developed in between PG&E’s EVM inspection and the Monitor team’s inspection).

ii. PG&E’s Internal Analysis

PG&E’s Quality Verification (“QV”) team also assesses the Company’s performance in the field under the EVM scope. The QV team reported its findings to the Monitor team, concluding that just shy of four percent of the mileage PG&E inspected did not conform with the EVM scope. Specifically, out of 42.82 work-verified miles inspected by PG&E, the Company reported that 96.17% of the segment mileage inspected met the requirements of the EVM scope. These results are consistent with the Monitor team’s findings—out of 32.09 work-verified miles inspected by the Monitor team in 2020, 93.27% of the segment mileage (not trees) inspected appeared to meet the requirements of the EVM scope.

c. Additional WMP Observations

PG&E tracks its progress against all 38 of its 2020 WMP commitments. This includes the commitment relating to EVM mileage targets discussed above, 12 commitments relating to grid design and system hardening, eight commitments relating to situational awareness and forecasting, and several others. While PG&E has either met—or is on track to meet—the vast majority of its


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2020 EVM commitments, as of early December 2020, PG&E has represented to the Monitor team that the Company believes it will not meet three of those 38 commitments.

The first commitment relates to the deployment of Sensor IQ technology to approximately 500,000 SmartMeters in HFTDs, as part of a pilot program. Sensor IQ technology enables PG&E to customize data reads and alarms with the goal of identifying service transformer failures and reducing the probability of a wildfire ignition. (March 2020 WMP, at 5-94.) PG&E reports that it has had issues with ensuring the compatibility of the technology, and that the Company will not be able to deploy the Sensor IQ technology as planned in 2020. Accordingly, PG&E requested a change order from the CPUC in September 2020, seeking a modification to this WMP commitment. (See Sept. 11, 2020 Ltr. From M. Pender to C. Thomas Jacobs, attached hereto as Ex. D.) The Company currently expects to deploy the Sensor IQ technology by June 1, 2021.

The second commitment relates to PSPS power restoration. In the 2020 WMP, PG&E stated that it sought to restore power more quickly to customers impacted by a PSPS event. In 2019, its goal was to restore power to impacted customers within 24 daylight hours from the weather “all clear” announcement. The weather “all clear” announcement is when PG&E determines that the adverse weather conditions prompting the PSPS event have sufficiently subsided and that energy restoration efforts—including inspections and repair work—can safely begin. This year, PG&E set a target in its WMP to restore power for 98% of affected customers within 12 daylight hours from the weather “all clear” announcement. (March 2020 WMP, at 5-287.) While PG&E met this target during the majority of its PSPS events in 2020, we understand from PG&E that it did not meet the targeted restoration time during the PSPS events on September 7-10 (91% restored within the 12-hour target) and October 25-28 (96% restored within the 12-hour target). And, across all customers impacted by all of the 2020 PSPS events, PG&E’s restoration rate within the 12-hour target was approximately 96%, which is slightly below the 98% target.

The third commitment relates to deploying partial voltage detection on 365,000 three-phase SmartMeters in HFTDs by the end of the year. (Id. at 5-91.) This enhancement enables PG&E to detect partial voltage or no voltage conditions before an outage may occur, and respond to downed distribution wires more quickly. (Id.) On December 11, 2020, PG&E requested a change order from the CPUC, stating that the Company identified a technical issue impacting the reliability of billing reads from the enhanced SmartMeters. (See Dec. 11, 2020 Ltr. From M. Pender to C. Thomas Jacobs, attached hereto as Ex. E.) PG&E expects to correct the issue and deploy the 365,000 enhanced SmartMeters before the start of the 2021 wildfire season.

There were other commitments that PG&E had identified earlier in the year as “at risk” of not being completed in 2020, but the Company has notified the Monitor team that there is a recovery plan in place and that it anticipates completing those by the end of the year. The Monitor team is continuing to track PG&E’s progress on all targets.

3. Compliance with Certain VM Regulations (Modified Probation Condition #1)

As noted above, the Monitor team’s field inspections are focused on assessing PG&E’s compliance with the EVM scope and providing related feedback, and not on making regulatory compliance determinations (the domain of the CPUC and PG&E’s other regulators). However, as


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described above, some of the potential EVM scope exceptions we identify through our inspections may also represent non-conformances with applicable VM regulations. Accordingly, in this section, we provide observations of where our inspections overlap with applicable regulatory requirements set forth in CPUC General Order 95 (“GO 95”) and California Public Resources Code Sections 4292 and 4293 (“Section 4292” and “Section 4293,” respectively).6

The Monitor team’s assessment is that PG&E’s VM programs appear to achieve compliance with applicable regulations that overlap with our EVM assessments in approximately 98.9% of cases (13,772 trees appeared to be in compliance out of 13,925 total trees we inspected). As to the remaining 1.1%, our inspections have identified areas where vegetation appeared to be out of compliance with applicable legal clearance requirements that overlapped with the EVM scope at the time of our inspections. Additionally, the Company acknowledges that it is unable to certify full compliance with applicable VM laws; it further states that doing so is impossible as a practical matter.

a. Observations Regarding EVM Overlap with Applicable Regulations

i. Section 4293 and GO 95

The Monitor team’s VM inspections in 2020 have included a review of 13,925 trees, and we have found 153 potential non-conformances with GO 95 that overlapped with the scope of our assessment of the Company’s EVM work, in that they presented potential hazard or radial clearance issues.7 Of those 153 potential non-conformances, 33 were located in State Responsibility Areas (“SRAs”) and were identified during fire season—therefore, they were also potential non-conformances under Section 4293. Our reporting that these trees were potentially out of conformance with GO 95 and/or Section 4293 is limited to our observation that the trees did not appear to comport with the applicable clearance requirements on the date of our inspection.8

Of the 153 potential regulatory non-conformances that we have identified in our 2020 inspections, 102 were potential hazardous condition non-conformances under GO 95—that is, our inspections identified trees or limbs that had line-strike potential and a risk of failure due to a defect as of the date of our inspection. 29 of the 102 potential hazardous condition non-conformances were in SRAs, identified during fire season, and were therefore potential non-conformances under Section 4293. For the Court’s reference, Exhibit G contains five examples (out of a total of 29) of such trees that were potentially in violation of the hazard clearance requirements under GO 95 and Section 4293. Examples provided to the Court in Exhibit G are 6 For the Court’s reference, attached as Exhibit F is a one-page summary of the relevant requirements of Section 4292, Section 4293, GO 95, and FERC/NERC FAC-003-4.

7 The 153 potential regulatory non-conformances discussed in this section are greater than the 74 potential EVM scope exceptions we identified on work-verified miles because the potential regulatory non-conformances are drawn from a larger sample, including inspections from all stages of EVM as well as areas where EVM has yet to occur.

8 Although the Monitor team observed that these particular trees did not appear to conform with applicable clearance requirements in Section 4293 and GO 95, the Monitor team has not independently assessed at this time whether these trees were ultimately mitigated within the timeframes specified under GO 95, Rule 18.


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also trees on which PG&E agreed with the Monitor team’s identification of the tree as a missed hazard tree under the EVM scope by PG&E inspectors.

Additionally, the remaining 51 potential regulatory non-conformances that we identified in 2020 were potential radial clearance non-conformances under GO 95—that is, our inspections identified trees (or limbs thereof) encroaching within four feet of the primary conductor or causing strain/abrasion on a secondary conductor in HFTDs as of the date of our inspection. Four of the 51 potential radial clearance non-conformances were in SRAs, identified during fire season, and were therefore potential non-conformances under Section 4293. For the Court’s reference, Exhibit H contains all four examples of such trees that were potentially in violation of the radial clearance requirements under GO 95 and Section 4293. Examples provided to the Court in Exhibit H include (i) three trees on which PG&E agreed with the Monitor team’s identification of the tree as a missed radial clearance issue by PG&E inspectors, and (ii) one tree on which PG&E’s response is pending.

ii. Section 4292 and FAC-003-4

As discussed above, the Monitor team’s VM inspections are primarily tailored to assessing compliance with the Company’s EVM scope. Compliance with Section 4292 (which mandates a firebreak zone around certain utility poles) is not included in the EVM scope, and is therefore not incorporated into our VM inspection protocol. However, our distribution overhead field inspections include a review for vegetation near the base of a pole that contains non-exempt equipment—PG&E’s equipment inspectors review for such vegetation as well. Our distribution overhead field inspection team identified three instances in 2019 (out of a total of 1,652 poles the Monitor team reviewed) where PG&E’s inspectors failed to identify vegetation within 10 feet of the base of a pole containing non-exempt equipment. These three instances likely constituted a non-conformance with Section 4292 because of the vegetation encroachment and because these instances were located in SRAs during fire season. Appended hereto as Exhibit I are reports from the Monitor team documenting these three potential non-conformances. The Monitor team appreciates that the work required in these three instances may have been subsequently identified and prescribed through a different PG&E program. However, we respectfully submit that the PG&E equipment inspectors that reviewed the three poles missed the issue, and that the three areas were likely out of compliance with Section 4292 as of the time of our field inspections.

With respect to FAC-003-4 (which reflects VM requirements for certain transmission lines), the Monitor team does not have a sufficient basis to independently assess PG&E’s compliance in 2020. Due to the fact that the EVM scope only applies to distribution lines and does not encompass transmission lines, we have prioritized and focused our VM field inspections—and corresponding feedback and analysis—on distribution lines. In 2021, we will be evaluating various efforts and initiatives that PG&E is undertaking around transmission vegetation management, COVID-restrictions permitting.


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iii. PG&E’s Statements and its Internal Assessments and Data

Regarding Compliance

PG&E internal assessments, which are based on a larger sample size than the Monitor team could inspect in 2020, reach similar conclusions—although regulatory compliance is not absolute, non-compliance is the exception.

Specifically, PG&E’s Quality Assurance (“QA”) team assessed a sample of 2020 VM work—including miles that had been pre-inspected, tree worked, or both—to assess compliance with the clearance requirements in Section 4292, Section 4293, GO 95, and FAC-003-4. As of December 9, 2020, the QA team had reviewed a total of 1,721.8 miles throughout PG&E’s service territory, which included a review of 84,300 trees. Of that review set, 668 miles (38.8% of the total miles reviewed) and 53,548 trees (63.5% of the total trees reviewed) were located in HFTDs.

The QA team found that, of the total population of 84,300 trees reviewed, 99.49% were in compliance with the clearance requirements in the four VM regulations, for a total of 432 non-conformances. For HFTDs in particular, PG&E’s QA team found that, of the total population of 53,548 trees reviewed, 99.54% were in compliance with the clearance requirements in the four VM regulations, for a total of 248 non-conformances.

Additionally, PG&E has represented to the Court on multiple occasions that—due to the dynamic nature of vegetation, the size of PG&E’s service territory, and other factors—the Company cannot guarantee strict compliance with applicable VM regulations at all times, or at any given point in time. See Dkt. 1132, p. 3 (“PG&E is unable to certify that it is in perfect compliance with all applicable regulations at any specific point in time.”); Dkt. 1016, p. 9 (“Given the dynamic conditions of vegetation, it is impossible for a utility to achieve perfect compliance or to represent that it is in full compliance at all times.”)

iv. Additional Compliance Observations

In May 2020, PG&E informed the CPUC that, between 2019 and April 2020, the Company identified approximately 1,900 trees that posed a “Level 1” risk under GO 95, Rule 18, which meant that they presented “[a]n immediate risk of high potential impact to safety or reliabilit y.” (May 14, 2020 Ltr. from L. Jordan to K. Kjensli, attached as Ex. J.) As such, they required “immediate” mitigation under GO 95, Rule 18. PG&E’s report to the CPUC stated that the Company failed to mitigate these Level 1 trees within the required timeframe, thereby violating GO 95 for each of the 1,900 instances, 157 of which occurred from January to April 2020. (Id.) The Company has since represented that it has mitigated all of these trees. In fact, following the Company’s self-report to the CPUC in May 2020, the Company has taken several steps to increase oversight and management of Level 1 trees, including daily calls to track mitigation plans. As a result, between May and November 2020 (i.e., following PG&E’s initial self-report to the CPUC in May 2020 and following the implementation of its corrective actions), there were far fewer trees (five in total) that PG&E identified for immediate mitigation that were not actually mitigated within 24 hours, the applicable remediation timeframe. However, all five trees were mitigated within 48 hours, and all involved circumstances purportedly beyond PG&E’s control, including: (i) a technical issue involving a delayed synchronization between a pre-inspector’s work device


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and the routine VM database; and (ii) certain trees that could not be safely worked without a de-energization/line drop, which required one additional day to schedule, according to PG&E.

Additionally, the Company recently revised its policy governing Level 1 or immediate-mitigation hazard trees to provide additional guidance and clarity regarding identification and mitigation of such trees, including by adopting a conservative approach to identification to err on the side of safety. For example, to ensure that Level 1 trees are mitigated within the required timeframe under GO 95, the contractor that identifies the Level 1 tree is required, where possible, to remain onsite until a mitigation plan is developed.

Additionally, as described in our October 16 Letter, we identified a tree with leaves that had singed from contact with the conductor, thereby posing an immediate safety risk and a potential Level 1 risk under GO 95. PG&E mitigated the tree on October 5. PG&E’s inspectors had previously identified this tree for urgent mitigation but had failed to mitigate it within the timeframe required by PG&E’s policies. We have enclosed as Exhibit K our October 4, 2020 report, which shows that the tree was in violation of the clearance requirements of GO 95 at the time of our inspection, and likely constituted a Level 1 immediate risk under GO 95.9

4. Recordkeeping Requirements (Modified Probation Condition #4)

PG&E is required to maintain “traceable, verifiable, accurate, and complete records of its vegetation management efforts.” (Dkt. No. 1040; Dkt. No. 1243.) Consistent with earlier observations that the Monitor team has shared with the Court—and consistent with our feedback to PG&E—there continue to be gaps in PG&E’s recordkeeping. Additionally, PG&E’s recent submissions to the Court regarding tree work near the origin of the Zogg Fire also reflect recordkeeping gaps. However, the Monitor team notes that the Company has made significant improvements since mid-2019.

a. Observations Regarding PG&E’s Compliance

The Monitor team has identified multiple instances of VM records defects, including records reflecting that VM work was completed when it was not. Our understanding of these issues is based in part on our use of PG&E’s recordkeeping systems when conducting field inspections, and our subsequent analysis of the data contained in those systems, which uniquely house certain records related to PG&E’s EVM efforts. We have shared and discussed our recordkeeping observations with PG&E on several occasions.

Additionally, notwithstanding the gaps and issues that we have identified with PG&E’s records, we note that PG&E’s recordkeeping processes have improved since mid-2019. For example, PG&E made major upgrades to its EVM database (Arc Collector) in September 2019 and March 2020, both of which significantly improved Arc Collector, including by: (i) enhancing data integrity by introducing measures to ensure that data was not erased or overwritten;

9 This tree is one of the 51 potential radial clearance non-conformances under GO 95 that we discussed in Section 3(a)(i) above.


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(ii) modifying and/or removing outdated data; and (iii) introducing more automated fields to help simplify and standardize data entry.

Examples of certain recordkeeping issues that we have observed are set forth below.

• Arc Collector Maps. As we noted in our letter to the Court on July 26, 2019 (Dkt. No. 1089), we identified inaccuracies in PG&E’s Arc Collector mapping tools. Since that letter, the Monitor team identified additional inaccuracies, including: (i) trees that are not accurately positioned on the map, or are otherwise located on an incorrect circuit segment; (ii) conductor lines that are not correctly located on the map; (iii) circuit segments with inaccurate starting and ending locations; and (iv) “phantom” circuit segments (i.e., circuit lines that appear in the Arc Collector map but do not actually exist). For the Court’s reference, Exhibit L contains five examples of such mapping inaccuracies observed by the Monitor team after its July 26, 2019 letter to the Court.

PG&E has been working to enhance the accuracy of its Arc Collector maps with Light Detection and Ranging (“LiDAR”) technology. Specifically, PG&E has been using LiDAR patrols to collect image data that helps identify and notate conductor lines and vegetation with greater precision, and thereby enhance the maps in Arc Collector. These LiDAR-enhanced maps have been used for certain circuits within Arc Collector, but they contain inaccuracies. On October 30, 2020, while conducting a vegetation inspection on a circuit that had recently been enhanced using LiDAR, we found various circuit segments in the field that were missing from the map. The Monitor team also identified a potential radial clearance exception within a missing circuit segment. We shared this observation with PG&E, and PG&E acknowledged that the LiDAR-enhanced maps have reliability issues. Thus, while the Monitor team appreciates PG&E’s efforts to use LiDAR-enhanced maps, we note that PG&E’s maps for EVM work are still not accurate and complete. For the Court’s reference, Exhibit H(2) contains the report where we identified a potential radial clearance exception on a missing circuit segment in an HFTD.

• Priority Hazard Tree Records, System Fragmentation, and Record Incompleteness. As described above, a Monitor team VM field inspection on October 4, 2020 identified a tree that was also identified for urgent work by the same PG&E pre-inspector twice in August 2020. However, the urgent work prescription was never recorded in the applicable VM database. That is, PG&E’s records that are used to identify—and assign work for—priority hazard trees did not reflect the operative prescription for the hazard tree and the pre-inspector’s corresponding observation. According to PG&E, the root cause of this issue is the fact that the pre-inspector that identified the tree was assigned to EVM and therefore could not directly prescribe certain hazard tree priority work because priority work is maintained in the routine VM database and prescribed accordingly. The routine VM database is separate from—and not synchronized with—the EVM database. Thus, a priority prescription by an EVM pre-inspector can only be made indirectly through a series of manual steps that have to occur outside of the EVM system; that did not occur in this instance. The Monitor team notes that PG&E is continuing to pursue a recordkeeping platform that will consolidate records relating to


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routine VM, EVM, and other VM programs. For the Court’s reference, our report of this October 4, 2020 potential radial clearance exception is attached as Exhibit K.

• Data Inconsistency. As we originally noted in our July 26, 2019 letter to the Court, Arc Collector has had data integrity problems, which resulted in duplicate assignments and the deletion of assignments. Similarly, as we noted to PG&E in July and December 2019, Arc Collector contained inconsistent data, including approximately 2,500 trees assessed as hazards that had conflicting notations of not needing work. In response, PG&E made major database upgrades. However, data inconsistency issues remain. For example, based on a recent review of Arc Collector data, the Monitor team found approximately 8,200 trees whose tree assessment scores indicate the tree needs to be removed, but were nevertheless marked as not requiring tree work. Conversely, we identified approximately 31,000 trees marked for removal—out of a total of approximately 1.7 million trees with associated data entries by pre-inspectors in Arc Collector—that were missing tree assessment scores, which are required to assess the tree’s hazard potential and which must be completed under PG&E’s own record integrity policies. The Monitor team has also observed trees in the Arc Collector database that passed EVM work verification despite missing tree assessment scores (which must be included in Arc Collector for a tree to pass work verification). All of these examples demonstrate conflicting, inaccurate, or incomplete data in PG&E’s EVM database. For the Court’s reference, Exhibit M contains six examples of such inconsistent or missing data in the EVM database. The Monitor team understands that PG&E plans to again update its Arc Collector system in the coming months and intends to assess the impact of those changes on data consistency.

• Incorrect Entries by Contractors. The Monitor team is aware of multiple instances where contractors incorrectly recorded in PG&E’s VM recordkeeping systems that work was completed, thereby rendering PG&E’s records inaccurate as to completed work. For example, in late 2019, the Monitor team identified nine potential exception trees whose tree status in Arc Collector indicated that tree-trimming work had been performed on those trees but which did not appear to have been worked. After reporting the issue to PG&E, the Company informed the Monitor team that one of its contractors had incorrectly certified these trees as having been worked. PG&E determined that eight of these inaccurate entries were due to a number of reasons, including: (i) the contractor misidentified the tree that required work and therefore did not work the correct tree; (ii) the contractor made mistakes in data entry; and (iii) there were miscommunications between the pre-inspector and the tree workers with respect to data entry. In May 2020, PG&E informed the Monitor team of another VM contractor who had incorrectly certified up to 38 trees as having been worked, largely due to confusion over paint markings and incomplete documentation of customer refusals. All of these instances resulted in PG&E’s records being inaccurate and incomplete. Despite these issues, PG&E deserves credit for the functioning of its internal controls in identifying and correcting these matters.


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i. Statements by PG&E

PG&E’s recent submissions to the Court regarding tree work near the origin of the Zogg Fire appear to reflect recordkeeping gaps. In particular, with respect to VM work that was completed following the Carr Fire, it appears that PG&E does not maintain the underlying records of the work completed, and that those records are instead retained by a PG&E contractor. (Dkt. No. 1265 at p. 23.) It appears that PG&E is therefore unable—based on records the Company maintains—to reconcile post-Carr Fire vegetation prescriptions and completed work with assignments and work completed through PG&E’s other VM programs. (Id.) Similarly, based on its own records, PG&E appears unable to ascertain the specifics of any Quality Control work that was done in the Carr Fire footprint, including the details of any findings and remediation work. (Id. at p. 24.) Additionally, as discussed in its filing, PG&E’s review of its contractor’s records suggests that the records may be inaccurate and/or incomplete in that they reflect two gray pine trees near the origin of the Zogg Fire that were identified for work, but do not appear to have been worked. (Id. at pp. 24-25.)

Relatedly, even though PG&E itself maintains records associated with CEMA and other routine VM work that was completed in the area of the Zogg Fire origin, PG&E’s filings suggest that those records also do not appear to be fully accurate and complete. Specifically, it appears that, in an attempt to stagger CEMA and routine VM inspections, patrols in the area near the Zogg Fire origin were assigned and re-assigned multiple times, ultimately resulting in a recordkeeping entry on April 4, 2019 stating that a CEMA patrol was scheduled to begin in February 2019 (approximately two months earlier), even though the patrol had not actually occurred in February 2019. (Id. at pp. 30-32.) In sum, the patrol that was assigned appears not to have been conducted, resulting in records that appear to be inconsistent, inaccurate, and incomplete at least in part.

5. Vegetation Management Inspector Program (Modified Probation Condition #6)

a. Overview

PG&E is required to build an internal Vegetation Management Inspector (“VMI”) program, with certain hiring deadlines in late 2020 and early 2021. Specifically, the Court has directed that:

PG&E shall, by September 1, 2020, staff an in-house vegetation management inspection manager to oversee a number of workforce resources who will provide in-field oversight of all stages of the vegetation management process, including the enhanced vegetation management program work, to be deployed throughout PG&E’s territory, including High Fire-Threat Districts. By the end of September 2020, PG&E will extend offers to 10 in-house field supervisors and/or inspectors, an additional 10 inspectors by the end of November, and the remaining approximately 10 inspectors by the end of January 2021.


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(Dkt. No. 1243.) The Court’s probation condition also provides additional details regarding: (i) the scope of VMI oversight for various phases of VM work; and (ii) recordkeeping and remediation requirements for any findings.

The Monitor team receives regular updates from PG&E regarding the status of the VMI program. Our assessment is that PG&E has thus far complied with the requirements set forth in the probation condition, and the Company continues to make progress towards operationalizing the VMI program.

b. Observations Regarding PG&E’s Compliance

PG&E has complied with the staffing requirements set forth by the Court. Specifically, by September 30, 2020, the Company had made offers to all seven VMI supervisors, along with offers to four VMIs—a total of 11 offers by September 30. All of these individuals have accepted their offers and joined PG&E. PG&E also made offers to an additional 11 VMIs by November 30, all of whom accepted. PG&E expects to onboard these individuals by January 4, 2021. Thus, by November 30, PG&E had extended offers to 22 individuals in total (seven supervisors and 15 VMIs). PG&E is currently interviewing additional VMIs. The Company reports that it is on track to make the remaining eight offers to VMIs by January 30, 2021, as required by the probation condition. All of these VMIs will report to a Manager that the Company hired on July 1, 2020, in advance of the September 1, 2020 deadline in the probation condition.

PG&E informed the Monitor team that it currently plans for the full VMI organization to include approximately 95 VMIs, seven supervisors, one Manager, and some additional support staff. The seven supervisors are PG&E employees. PG&E estimates that 30 of the VMIs will be PG&E employees, and that the remaining 65 VMIs will be contractors. Including supervisors and VMIs, the program will include approximately 37 direct PG&E employees, exceeding the requirement of 30 employees listed in the probation condition.

PG&E is still developing processes for the VMI program—including trainings, work assignments, recordkeeping systems, and oversight mechanisms—and expects that the program will be operational by the first quarter of 2021. PG&E anticipates that all new VMIs will begin a six-week orientation and training regime starting January 4, 2021, including in-field and classroom trainings and assessments. PG&E is also designing and testing its recordkeeping platform for VMIs to document their field observations. Additionally, to assist with training and process development, supervisors and VMIs have started conducting limited field inspections.

The Monitor team will continue to assess PG&E’s progress as it develops the new VMI program, and we look forward to evaluating the program once deployed in early 2021.

Conclusion

PG&E has taken important steps to change its trajectory for 2021 wildfire mitigation work planning and execution, including its EVM work, to ensure that the selected work prioritize risk reduction according to its models ahead of other considerations. The Monitor team has been encouraged by the steps PG&E has taken thus far regarding the 2021 planning process and its risk


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focus. While PG&E’s planning efforts are underway, our assessment above highlights the need to continue to focus on quality of execution and records integrity—notwithstanding that PG&E is compliant with the EVM scope in most circumstances. The Monitor team continues to identify deviations from PG&E’s EVM scope throughout all stages of the EVM process, including following its work-verification efforts; some of those deviations also overlap with applicable vegetation regulations; and the Monitor team continues to identify recordkeeping gaps at PG&E. The Monitor team will continue to assess PG&E’s EVM and related efforts moving forward.

Should the Court have any questions, please do not hesitate to reach out.

Sincerely,

Mark Filip


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ENHANCED OVERSIGHT AND ENFORCEMENT PROCESS

CORRECTIVE ACTION PLAN

90-DAY REPORT

PURSUANT TO RESOLUTION M-4852

AUGUST 4, 2021

PUBLIC VERSION

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Table of Contents

Page

Executive Summary ..................................................................................................................... 2

Corrective Action Plan Elements ................................................................................................. 3

Element 1 .......................................................................................................................... 3

Element 2 .......................................................................................................................... 3

Element 3 .......................................................................................................................... 4

Element 4 .......................................................................................................................... 9

Element 5 .......................................................................................................................... 9

Element 6 ........................................................................................................................ 14

Element 7 ........................................................................................................................ 15

Element 8 ........................................................................................................................ 15

Element 9 ........................................................................................................................ 16

Element 10 ...................................................................................................................... 16

Element 11 ...................................................................................................................... 16

Element 12 ...................................................................................................................... 16

Element 13 ...................................................................................................................... 16

Element 14 ...................................................................................................................... 17

Conclusion .................................................................................................................................. 18

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List of Attachments

Attachment E Updated 2021 Enhanced Vegetation Management Scope of Work

Attachment J Updated Verification of Sumeet Singh

Attachment K GIS Data for 2021 Enhanced Vegetation Management Scope of Work1

Attachment L Enhanced Vegetation Management Work to be Performed in Next 90 Days

Attachment M Resources and Personnel for Next 90 Days

Attachment N 2021 EVM Work Performed Outside the 2021 EVM Scope of Work

Attachment O Action Plan in Response to Internal Audit Report

1 Attachment K is provided in a separate zip file.

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2

Pacific Gas and Electric Company (PG&E) respectfully submits this August 4, 2021 90-Day Report (August Report) updating its Corrective Action Plan in response to Ordering Paragraph 3 in Resolution M-4852 issued by the California Public Utilities Commission (Commission) on April 16, 2021 (Resolution). In this August Report, we provide updated information where applicable to each of the elements in the Resolution. We are also providing two updated Attachments from the Corrective Action Plan and several new attachments in response to Commission requests.2

EXECUTIVE SUMMARY

We submitted our Corrective Action Plan on May 6, 2021. Since that time, we have responded to discovery and on June 23, 2021, the Commission hosted a workshop to review the Corrective Action Plan. We appreciated during the workshop the active participation of and feedback from President Batjer, Commissioners Shiroma and Rechtschaffen, Executive Director Peterson, Office of Energy Infrastructure Safety (OEIS) Director Thomas Jacobs, OEIS Staff, Safety and Enforcement Division (SED) Staff, and parties. The feedback provided was very helpful for our continued implementation of the Corrective Action Plan.

While we understand that there is a long way to go in achieving the Enhanced Vegetation Management (EVM) goals set forth in our 2021 Wildfire Mitigation Plan (WMP) and 2021 EVM Scope of Work, with the dedicated efforts of our employees and contract partners, we are making substantial progress implementing our 2021 EVM program. Through June 30, 2021, we had completed and verified 595.5 miles of EVM work toward our goal of 1,800 miles.3 More importantly, the vast majority of this work was performed on CPZs in high risk miles so that we can achieve our goal of performing at least 80% of our work in the highest 20% of risk ranked CPZs. As indicated in Table 1 below, more than 95% of the EVM work completed through June 30, 2021 was in the highest 20% of risk ranked CPZs.

2 For consistency, we have labeled the updated attachments with the same letter that was used in the Corrective Action Plan so that, for example, Attachment E included with this August Report is an updated version of Attachment E included with the Corrective Action Plan. For new attachments, we have started the letter to follow the attachments in the Corrective Action Plan so the first new attachment starts with Attachment K. 3 The 595.5 miles includes: (1) 512.4 miles on the 104 Circuit Protection Zones (CPZs) in our 2021 EVM Scope of Work which are identified in Attachment E to this August Report; and (2) 83.1 additional miles of EVM work on CPZs outside the 2021 EVM Scope of Work. A breakdown of the risk ranking for the EVM work performed to date is included in Table 1. For ease of reference, in the narrative portions of the August Report we will refer to 596 miles of EVM work completed as of June 30, 2021, rounding 595.5 up to 596.

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Table 1: EVM Progress Through June 30, 2021

Risk Tranche Work Verified (WV) Miles % of Total WV Miles

< = 10% 551.2 92.5%

> 10 – 20% 17.7 3.0%

> 20 – 30% 7.3 1.2%

> 30 – 40% 6.3 1.1%

> 40 – 50% 8.6 1.5%

> 50% 4.4 0.7%

Total 595.5 100.0%

In addition to the work performed, we are increasing the frequency of communication with our employees and contract partners and are also making sure that this is two-way communications so that information flows from the field to the leadership team and vice versa. This kind of frequent, two-way communication is critical to the success of our EVM program.

The remainder of this August Report provides an update on the fourteen elements in the Corrective Action Plan. We look forward to continuing our work with the Commission, SED, OEIS, and interested parties to continue to refine and improve our EVM program.

CORRECTIVE ACTION PLAN ELEMENTS

1. A detailed description of the circumstances that contributed to PG&E’s failure to adequately prioritize the highest risk lines, as described in this Resolution and the WSD’s EVM Audit, in its EVM in 2020

We do not have any updated information to provide regarding this Element.

2. A detailed description of its risk model(s) for determining where to target EVM in the next 90 days, including the specific data sets and vegetation management records PG&E is using as inputs to the risk model, and the data modeling program(s) that make up PG&E’s risk model


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3. A detailed list of the EVM projects for the calendar year of the reporting date and the EVM plan for the subsequent calendar year, when available

In this August Report, we are providing the following: (a) updated status on the 2021 EVM Scope of Work and progress to date; (b) the addition of the San Joaquin #2 1103circuit_breaker CPZ to the 2021 EVM Scope of Work; (c) information responsive to SED’s and OEIS’ first set of data requests; and (d) the status of the 2022 EVM Scope of Work.

a. Updated Status of the 2021 EVM Scope of Work

We included our 2021 EVM Scope of Work as Attachment E to the Corrective Action Plan and are including as Attachment E to the August Report an updated version of the 2021 EVM Scope of Work. Attachment E includes information concerning the CPZs in our 2021 EVM Scope of Work and the status of work on these CPZs. For each CPZ, we are providing the total EVM miles, the miles completed as of June 30, 2021, miles ready for verification as of June 30, 2021, and information concerning miles impacted by customer refusals, permitting, environmental issues, and other constraints.

There are five issues related to Attachment E (i.e., the 2021 EVM Scope of Work) that we wanted to make sure to highlight for clarity.

First, the 2021 EVM Scope of Work includes five CPZs that were not identified in the 2021 EVM Scope of Work that we submitted on May 6, 2021 with the Corrective Action Plan. Specifically, the updated 2021 EVM Scope of Work includes the San Joaquin #2 1103circuit_breaker CPZ which was erroneously excluded from the earlier 2021 EVM Scope of Work. The addition of this CPZ is discussed in Element 3(b). We have also added four CPZs based on commitments and permitting. In addition to the five CPZs added to the 2021 EVM Scope of Work, we also reprioritized one CPZ based on a commitment. These additions and reprioritization are addressed in Element 6. Table 2 below summarizes these changes:

Table 2: Updated CPZs in 2021 EVM Scope of Work

2021 EVM Scope of Work (May 6, 2021)

2021 EVM Scope of Work (August 4, 2021)

Total Risk Ranked CPZs 99 1004

Total Commitment/Permitting CPZs 0 45

Total CPZs in 2021 EVM Scope of Work 99 104

4 San Joaquin #2 1103circuit breaker added as discussed in Element 3(b). 5 Discussed in Element 6.

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Second, the total mileage in the 2021 EVM Scope of Work provided on May 6, 2021 for the 99 CPZs identified was 2,422.4 miles. As we review our records and confirm mileage for a CPZ or facilities are added or removed, the mileage associated with a CPZ may vary slightly.

Third, we are providing information in the August Report that is as of June 30, 2021 because we have not yet completed the audit process for EVM data reported after June 30, 2021.

Fourth, the updated 2021 EVM Scope of Work includes EVM work performed on a risk ranked basis. However, as we explained in the Corrective Action Plan, we did perform some carry-over EVM work in early 2021, as well as work based on the earlier March 2021 EVM Scope of Work.6 Thus, the 596 miles of EVM work verified and completed through June 30, 2021 is greater than the 513 miles verified and completed in the updated 2021 EVM Scope of Work. In order to provide a complete picture of the EVM work verified and completed to date, we are including as Attachment N a list of the EVM work performed through June 30, 2021 that is outside the 2021 EVM Scope of Work. Table 3 below summarizes the EVM completed and verified miles through June 30, 2021 that are within the 2021 EVM Scope of Work and those miles performed on CPZs outside the 2021 EVM Scope of Work.

Table 3: Miles of EVM Work Completed In and Outside 2021 EVM Scope of Work

CPZ Category August Report Attachment

Miles of EVM Completed and Verified (Through 6/30/2021)

In 2021 EVM Scope of Work Attachment E 512.4

Outside 2021 EVM Scope of Work Attachment N 83.1

Total 595.5

Finally, PG&E’s Internal Audit (IA) department is actively involved in reviewing and validating EVM work in 2021. However, the IA review and validation takes time. To provide clarity on the information that has been audited, we have included in the column headers in Attachments E and N the audit status of the information in the column. Additional data will be audited as a part of our validation process and the final number of miles of EVM work completed by December 31, 2021 will be fully audited.

6 Corrective Action Plan, p. 23 and Attachment G describing differences between March 2021 EVM Scope of Work and the 2021 EVM Scope of Work included in our Corrective Action Plan.

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b. Addition of San Joaquin #2 1103circuit_breaker CPZ

In developing our 2021 EVM Scope of Work, several sets of data were combined to produce the risk rankings in the EVM tree-weighted prioritization list. The primary datasets included:

1. Risk Pixel data, aggregated by Unified Grid areas;

2. CPZ data, showing the Unified Grid areas that each CPZ intersects;

3. Light Detection and Ranging (LiDAR) data showing the number of LiDAR detected trees on each circuit in each Unified Grid area; and

4. EVM data showing the amount of work identified and performed on each circuit in each Unified Grid area.

When these datasets were merged, some of the circuit names were not consistent. As a result, several San Joaquin circuits were inadvertently assigned a value of zero remaining EVM miles.

As a part of our continuing validation efforts, our operations group reviewed the data in the 2021 EVM Scope of Work and noted that based on their experience in the field and understanding of the risk models, the San Joaquin circuits should have been in the highest risk-ranked CPZs. To understand why the San Joaquin circuits were not included, we re-examined our analysis and focused specifically on the San Joaquin circuits.

The data review showed that the EVM data had a mismatch in the circuit names for four circuits:

SAN JOAQUIN NO2 1103 (in other data sets shows up as SAN JOAQUIN #2 1103)




As a result of this circuit name mismatch, the EVM Remaining Miles and EVM Remaining Tree work were not matched in the tree weighting calculations, causing the CPZs on those circuits to be incorrectly ranked in the EVM tree-weighted prioritization list. This circuit name mismatch only materially impacted the ranking of the two CPZs identified in Table 4 below.

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Table 4: San Joaquin CPZ Revised Risk Ranking

Original Risk Ranking

New Risk Ranking Circuit Name Circuit Protection Zone

Remaining EVM Miles

2765 (bottom 50%) 40 (top 10%) San Joaquin NO2 1103

San Joaquin #2 1103circuit_breaker

67.31

2751 (bottom 50%) 104 (top 10%) San Joaquin NO2 1103

San Joaquin #2 110310320

11.23

Because the 2021 EVM Scope of Work only included the top 99 risk ranked CPZs, we have only added to the San Joaquin #2 1103circuit_breaker CPZ which has a new risk ranking of 40. This has resulted in our 2021 EVM Scope of Work in Attachment E now including the top 100 risk ranked CPZs (i.e., the original 99 risk ranked CPZs plus San Joaquin #2 1103circuit_breaker).7

In addition to reviewing the San Joaquin CPZs, we also performed an extent of condition analysis and did not find any other CPZs that should be added to the 2021 EVM Scope of Work as a result of the name mismatch described above. However, this situation highlighted the need for a sensitivity analysis that would provide an assessment of the risk that an inaccurate ranking had occurred because of missing or mismatched data. Thus, we have added a sensitivity analysis to our review process that provides this assessment. At a high level, the sensitivity analysis uses the raw risk scores in the geographic areas and calculates how many trees would need to be observed in that broader general area for the EVM tree-weighted prioritization list to be materially impacted. The analysis can point out areas where there is a potential for data loss from tree information or EVM mileage information. Those areas identified as having potential data loss can then be investigated further and, if there is a data loss, corrections made. Had this sensitivity analysis been performed on the initial output, the San Joaquin circuit areas would have been observed to be an area that would have required further investigation, and the circuit naming mismatch would have been identified and corrected.

c. Responses to SED/OEIS Data Request Set #1, Request No. 20(a)-(d)

In their first set of data requests, SED and OEIS identified in Request No. 20 five items that we should include in our August Report. Four of these items are discussed below. The fifth item is discussed in Element 5.

(1) GIS Data

7 We have also added four CPZs to our 2021 EVM Scope of Work based on commitments and permitting, as described below in Element 6, so the total number of CPZs in the 2021 EVM Scope of Work is 104 CPZs.

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SED and OEIS requested “GIS data to map out where the EVM work will be performed” including the location in each of the CPZs in the 2021 EVM Scope of Work and the status of work completed. This information is provided in Attachment K, which is a zipped file that contains the underlying data.

(2) Wildfire Risk Governance Steering Committee (WRGSC)-Recommended Changes to the Corrective Action Plan and Wildfire Mitigation Plan

SED and OEIS also requested information on any changes recommended by the WRGSC to the Corrective Action Plan or our 2021 WMP. Since May 6, 2021, the WRGSC has not approved any changes to the Corrective Action Plan or the 2021 WMP that directly impact the EVM program for 2021. However, the WRGSC has approved changes to the 2021 EVM Scope of Work. On July 9, 2021, the WRGSC approved the addition of San Joaquin #2 1103circuit_breaker CPZ, as described in Element 3(b) above. In addition, the WRGSC approved the addition of four CPZs to the 2021 EVM Scope of Work for commitments/permitting and the reprioritization of one CPZ. These changes are described in Element 6 below.

(3) EVM Work to be Performed in the Next 90 Days

SED and OEIS also requested a spreadsheet that identifies all CPZs that will be worked within the next 90 days beginning August 4, 2021. This information is provided in Attachment L.

We are also including with Attachment L work that was performed between July 1, 2021 and August 6, 2021. This information was requested in SED and OEIS data requests and so, for completeness and ease of reference for the parties, we are providing it in a single Attachment to the August Report.8

(4) Information Regarding Personnel and Resources for EVM Work

Finally, SED and OEIS requested specific information regarding resources and personnel for the EVM work to be performed in the next 90 days starting August 4, 2021 including: (1) supervisors per region; (2) contractors per supervisor; (3) foreman per contracting company; (4) field employees per contracting company; and (5) which contracting companies are assigned to specific CPZs. Although most of this information is provided in Attachment M, the number of contractors per supervisor can vary substantially as EVM work in a region is completed and thus PG&E is not able to forecast the number of contractors per supervisor over the next three months. In addition, Attachment M includes confidential third-party staffing information and thus we are providing a public version of Attachment M with the third-party staffing information

8 The numbers in Attachment L have not yet been reviewed and validated by PG&E’s IA Department.

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redacted and are providing a confidential version of Attachment M to the Commission, SED and OEIS.

d. Status of the 2022 EVM Scope of Work

In our Corrective Action Plan we indicated that we have “a goal to complete the final, WRGSC-approved 2022 EVM Scope of Work in Q4 2021.”9 We also indicated that “[i]n December 2021, we plan to revise the approved 2022 EVM Scope of Work to account for work that has been completed in 2021, incorporate all the permit delays and customer refusals, and refresh the CPZ listing to ensure focus on the highest risk miles in 1-n ranking approach.”10

Given our current focus on and efforts toward making sufficient progress on the 2021 EVM Scope of Work, we have not started the planning yet for the 2022 EVM Scope of Work. However, we fully intend to meet the 2022 EVM Scope of Work timing described in our Corrective Action Plan.

4. A description of how the list in item 3 above ensures PG&E is prioritizing the power lines with highest risk first

As we explained in the Corrective Action Plan, “[t]he 2021 EVM Scope of Work is based on the risk-ranked CPZs from the EVM tree-weighted prioritization list.”11 In Element 3 above, we have provided an updated status of our 2021 EVM work as of June 30, 2021. By the end of the year, based on our 2021 EVM Scope of Work, we plan to have executed EVM work on the highest risk ranked circuits, except where we are unable to do so because of customer refusals, permitting issues, or other external factors that impact our ability to perform EVM work. This approach ensures that PG&E is prioritizing the highest risk CPZs before lower ranked CPZs. We will also have performed work related to commitments/permitting, as discussed in Element 6 below. Finally, a small portion of the 2021 EVM work will have been carried over from 2020. As Table 1 in the Executive Summary indicates, through June 30th almost 95% of our EVM work was performed on the top 20% of risk ranked CPZs.

5. A description of PG&E’s decision-making that leads to the list in item 3: how the list is developed, evaluated, revised in terms of projects that are added to or dropped from the list, finalized, and communicated to EVM work crews, and PG&E’s internal documentation of the decision-making process

In Element 5, we provide updated information on: (a) the development and revision of the 2021 EVM Scope of Work; (b) communication with EVM work crews; (c) internal documentation of

9 Corrective Action Plan, p. 18. 10 Corrective Action Plan, p. 18. 11 Corrective Action Plan, p. 18.

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decision-making; and (d) our action plan to address issues identified in our May 21, 2021 Internal Audit Report.

a. Development and Revision of 2021 EVM Scope of Work

In our Corrective Action Plan, we described how the 2021 EVM Scope of Work was developed.12 We also described the process for updating the 2021 EVM Scope of Work.13 There are no updates to how the 2021 EVM Scope of Work was developed or the process for revising it.

However, as described in Elements 3 and 6, there have been revisions to the 2021 EVM Scope of Work since we submitted the Corrective Action Plan on May 6, 2021. These changes include the addition of the San Joaquin #2 1103circuit_breaker CPZ (described above in Element 3(b)), the addition of four CPZs for commitments/permitting, and the reprioritization of one CPZ (described below in Element 6).

b. Communication with EVM Employees and Contractors

We discussed our communications with EVM crews regarding the 2021 EVM Scope of Work in the Corrective Action Plan and at the June 23, 2021 workshop.14 In this section we are providing updated and more detailed information regarding EVM communications.

As an initial matter, it is important to understand that our communications are not one way (i.e., from EVM management to the crews). Our crews and contractors performing EVM pre-inspections, work, and verification learn critical information and lessons in the course of their work that is essential to the success of our EVM program. A regular cadence of open and transparent meetings take place so that information can flow from the field to management and from management to the field.

For internal communications, EVM goals and targets are communicated to teams and individual staff members through daily communication that includes updates regarding EVM work progress and targets. Daily Operating Reviews (DOR) are held daily at multiple levels within our organization. We have a DOR among our officer and leadership team and a DOR at the region level with all of our regions represented and attended by the EVM leadership team. At the region-level DOR, our field teams and leadership discuss progress with the 2021 EVM Scope of Work. The purpose of the DORs is to discuss challenges and counter measures to keep the plan on track. On July 13, 2021, we held our first monthly Vegetation Management (VM) All Hands meeting to review the 2021 EVM Scope of Work, progress, constraints and changes.

12 Corrective Action Plan, pp. 12-15. 13 Corrective Action Plan, pp. 15-17. 14 Corrective Action Plan, pp. 23-24.

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After every quarter, an All-Hands meeting will discuss a summary of overall progress on the 2021 EVM Scope of Work in the past quarter and discuss goals for the next quarter.

For communications with our EVM contractors, we have dedicated PG&E EVM personnel who are responsible and accountable for communicating the work to be released. This team manages the scope through completion to ensure it aligns with the 2021 EVM Scope of Work. Based on the direction given by our personnel, contractors are responsible for managing their workforce to complete the work scope per the schedule.

c. Internal Documentation of Decision Making

The Vegetation Management Change Control Board (VM Board) is scheduled to meet twice a month if needed to review the status of EVM work, risk, financial information, and commitments, as well as to discuss any potential changes to the 2021 EVM Scope of Work. If the VM Board approves a recommendation to modify the 2021 EVM Scope of Work, that recommendation is then presented to the WRGSC. The VM Board communications are documented through e-mails, and decisions are documented in the EVM Change Control Form which is discussed more below.

The WRGSC meets weekly, and more frequently if needed. Meeting outcomes are documented following the meeting and final materials that include decisions, action items and the meeting presentations (with any requested edits incorporated) are sent to attendees following the meeting.15

The documentation process for changes to the 2021 EVM Scope of Work is described in the EVM Change Control Process and Change Control Communication below.

(1) EVM Change Control Process

The following steps outline the process for reviewing and approving changes to the 2021 EVM Scope of Work, and the process for documenting these changes, to ensure transparency and alignment across the organization. These steps are reflected in Figure 1, below which depicts graphically the change control process.

1. Stakeholder(s) within the Vegetation Management organization identify CPZ(s) and any associated mileage for inclusion or exclusion from the EVM workplan for a given execution year based on the aforementioned criteria. The stakeholder(s) fills out the required information in the EVM Change Control form.

15 For additional information regarding the responsibilities of the VM Board and WRGSC and communication between the VM Board and WRGSC, see Corrective Action Plan, pp. 16-17.

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2. The Vegetation Management stakeholder(s) emails the completed form to the VM PMO team to initiate the EVM workplan change request.

3. The VM PMO team works to analyze the information provided in the EVM Change Control form and develops a recommendation for CPZ(s) to replace the excluded CPZ(s) or CPZ(s) to withdraw from the current EVM workplan to accommodate newly included CPZ(s). The VM PMO team will work in coordination with the Vegetation Management stakeholder(s) to confirm alignment on the recommendation.

4. VM PMO presents their recommendation and modified EVM workplan to the VM Board.

5. The VM Board evaluates the proposed recommendation and modified EVM workplan.

6. The VM Board will approve or reject the proposed recommendation:

a. If approved, the decision is documented and communicated to the VM Board.

b. If the VM Board denies the proposed recommendation, the VM PMO team will update the EVM Change Control form to reflect the VM Board’s decision.

c. If the VM Board requests additional information, the change request will be remanded to the VM PMO team to address the feedback and/or revise the recommendation.

7. The WRGSC evaluates the proposed recommendation and modified EVM workplan.

8. The WRGSC will approve or reject the proposed recommendation:

a. If approved, the decision is documented and communicated to the VM Board.

b. The WRGSC may deny the proposed recommendation or request additional information. If additional information is requested, it is returned to the VM PMO team to address the feedback and/or revise the recommendation (Step 3).

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9. VM PMO prepares the modified EVM workplan for dissemination to the appropriate Vegetation Management stakeholder(s).

10. VM PMO uploads the completed EVM Change Control form to SharePoint.

Figure 1: EVM Change Control Process

(2) EVM Change Control Communications

For recordkeeping purposes, communications during the EVM Change Control process are documented via email and/or signed attestations on the EVM Change Control form to reflect decisions or acknowledgements made during in-person meetings. For example, VM PMO may discuss EVM workplan modifications during weekly, biweekly, or monthly meetings held with PG&E local operations and contractor leadership, accounting team, and operations. Any new change requests must be recorded and submitted on an EVM Change Control form prior to initiating the Change Control process, and signed acknowledgement of receipt for a modified EVM workplan must also be documented on the appropriate EVM Change Control form.

(d) Response to Internal Audit Report

In their first set of data requests, Request 20(e), SED and OEIS requested the action plan for issues identified in an IA Report from May 21, 2021. IA evaluated processes and controls over development of the Tree-Weighted Prioritization List being used to inform the 2021 EVM Scope of Work. All of the issues identified in the IA Report were resolved prior to the report being issued with the exception of one issue related to a known limitation concerning the aggregation of risk scores for CPZ ranking. The Action Plan to address this remaining item is included as Attachment O.

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6. An explanation of the rationale for any planned EVM work that does not target the power lines with highest risk first

Although the 2021 EVM Scope of Work is based on performing work on the highest risk-ranked CPZs, as we explained in our Corrective Action Plan there is some EVM work that it is reasonable and prudent to perform even if it is not the highest risk-ranked work.16 Between the submission of the Corrective Action Plan on May 6, 2021 and this August Report, there have been four CPZs related to commitments/permits added to the 2021 EVM Scope of Work which are identified in Table 5 below:

Table 5: Commitments/Permits Added to 2021 EVM Scope of Work

Project Region Risk Tranche

Description of Commitment and Basis for Commitment

San Luis Obispo 1107

San Luis Obispo 1107v60

Central Coast > 20%

Commitment was made by the local Vegetation Program Manager and engaged by our Local Public Affairs to internal and external parties of the Diablo Canyon Power Plant and Avila Valley Advisory Council (AVAC). There is a narrow ingress/egress, little to no cell service in this territory, and recently a small (non-equipment failure) fire in this area.

Silverado 2104

Silverado 210478268

Bay Area Top 10%

Commitment was made by PG&E Regional Manager and Supervisor Program Manager to CalFire & Las Posadas State Forest CalFire, Las Posadas State Forest, Las Posadas Community College, Angwin Community. This is the one of the few areas in the Napa area that have not been affected by a recent wildfire.

Bell 1107

Bell 110750172 Sierra Top 10%

Permit expires 10/2/2022. Commitment made by Vegetation Program Manager to customers.

Yosemite Division – USFS

Wishon 1101circuit_breaker

Central Valley Top 20%

Environmental permit with the U.S. Forest Service expires 10/27/2021

16 Corrective Action Plan, pp. 18-19.

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In addition, one CPZ that was in the 2021 EVM Scope of Work, but not a part of the initial 1,800 miles, has been re-prioritized so that it is part of the 1,800 mile plan as a result of commitments related to that CPZ. As we explained in the Corrective Action Plan, our 2021 EVM Scope of Work includes a plan to perform work on 1,800 miles of CPZs as well as an additional 600 miles that can be substituted for any miles in the highest risk 1,800 miles if we are unable to perform work on any of these 1,800 miles, subject to WRGSC review and approval.17 The Girvan 1101 CPZ was included in the 600 additional miles identified in our 2021 EVM Scope of Work submitted on May 6. However, as a result of a commitment related to this CPZ, the WRGSC approved including the Girvan 1101 CPZ in the 1,800 miles for the 2021 EVM Scope of Work. Adding Girvan 1101 will not replace any other CPZ in the 1,800 miles of planned work but will instead be in addition to the CPZs identified as the initial 1,800 miles. Information regarding the Girvan 1101 CPZ is provided in Table 6 below.

Table 6: CPZ Reprioritized in 2021 EVM Scope of Work Based on Commitments

Project Region Risk Tranche

Description of Commitment and Basis for Commitment

Girvan 1101

Girvan 11011330 North Valley Top 10%

Commitment was made to Judge Alsup and a Public Safety Specialist by PG&E and the Fire Marshall and a part of the extent of condition related to the Zogg Fire.

7. Any changes to the 2021 Wildfire Distribution Risk Model, the Wildfire Consequence Model, or the Vegetation Risk Model occurring over the prior 90 days or planned for the subsequent 90 days

We did not make in the past 90 days and do not plan on making in the next 90 days any changes to the 2021 Wildfire Distribution Risk Model, Wildfire Consequence Model, or Vegetation Risk Model for purposes of the 2021 EVM Scope of Work or informing EVM work in 2021.

8. A detailed description of the circumstances that contributed to PG&E management’s inconsistent reporting on the details of its risk modeling and risk ranking lists


17 Corrective Action Plan, p. 14.

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9. Verification by a senior officer of PG&E that the risk model, including underlying data sets and vegetation management records, it is using to prioritize EVM is as set forth in its report

We are providing an updated version of Attachment J, which was the verification included in the Corrective Action Plan, with this August Report.

10. Verification by a senior officer of PG&E that it will target a substantial majority of EVM to the highest risk circuit protection zones first, as shown by its risk model or other ranking, in the next 90 days for EVM


11. Verification by a senior officer of PG&E that it targeted a substantial majority of EVM to the highest risk circuit protection zones first, as shown by its risk model or other ranking, in the prior 90 days


12. Verification by a senior officer of PG&E that the company has communicated information and internal decisions in items 3, 4 and 9 above to personnel of PG&E’s EVM programs and that such personnel is aware of where to target EVM in the subsequent 90 days


13. A proposed timeline for ending the required reporting, with a detailed explanation of why the proposal ensures PG&E is in compliance with the requirement that it prioritize high risk circuits in its EVM work. The timeline shall include milestone goals for June 1, 2021, September 1, 2021, and December 31, 2021. These goals shall include a targeted percentage of high-risk power line circuits to be completed by those dates.

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In the Corrective Action Plan, our goal was to complete 210 high risk miles18 by June 1, 2021. We achieved this goal by completing 363 high risk miles19 of completed and verified EVM work by June 1, 2021. Table 7 below provides an update on our 2021 EVM goals.

Table 7: Update on Goals for EVM Work in 2021

Date Corrective Action Plan Goal for High

Risk Miles

Corrective Action Plan Goal for

Percentage Completion20

Actual High Risk Miles

Actual Percentage Completion

June 1, 2021 210 11% 363 20%

September 1, 2021 850 47% - -

December 31, 2021 1,800 100% - -

We are not proposing any changes to our September 1 and December 31, 2021 goals, nor are we proposing any changes to our proposal that the reporting related to EVM performance end in February 2022.21

14. A description of how the Corrective Action Plan proposed in response to this Resolution will complement and not undermine PG&E’s compliance activities ordered in the D.20-05-019


18 High risk miles are defined as the top 20% of CPZs based on risk ranking from the EVM tree-weighted prioritization list and fire impacted miles. 19 For purposes of this Corrective Action Plan, high risk miles are defined as the top 20% of CPZs based on risk ranking from the EVM tree-weighted prioritization list and fire impacted miles (i.e., locations where wildfire will burn through an area leaving trees that need to be trimmed or removed). The 363 high risk miles are based on a snapshot of data from July 1, 2021. 20 Percentage completion is based on a goal of approximately 1,800 miles of EVM work performed by the end of 2021. 21 Corrective Action Plan, pp. 24-25.

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CONCLUSION

This August Update provides an overview of events which have occurred in the 90 days since we submitted the Corrective Action Plan. We appreciate the opportunity to provide these updated materials to the Commission, WSD, SED, and stakeholders and look forward to receiving continued feedback on our approach to focusing the EVM program on the highest risk CPZs in our service territory.

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PACIFIC GAS AND ELECTRIC COMPANY

ATTACHMENT E

UPDATED 2021 ENHANCED VEGETATION MANAGEMENT

SCOPE OF WORK

APP3-68

Circuit Name Circuit Protection Zone Remaining EVM Miles Forecasted Tree Work Tree Weighted Risk Score Tree Weighted Rank Plan (Mile Cutoff)Miles Complete and Verified as

of 6/30/21(Audited)

Miles Ready for Work Verification as of 6/30/21 (Unaudited)

Miles Constrained Customer Refusals

(Unaudited)

Miles Constrained Permitting Holds (Unaudited)

Miles Constrained Environmental Holds

(Unaudited)

Miles Constrained Other (Unaudited)

Remaining Miles (Unaudited)

Risk Milesby Percentage(Top 20%)

RIO DELL 1102 RIO DELL 11024230 22.82 4236.60 202.04 1 1800 MILE 1.71 0.07 0.84 0.00 11.53 0.09 8.58 1. <= 10%APPLE HILL 2102 APPLE HILL 2102circuit_breaker 38.41 4581.57 175.16 2 1800 MILE 4.04 0.75 1.90 0.00 1.17 0.00 30.55 1. <= 10%FORT SEWARD 1121 FORT SEWARD 11211690 10.43 1715.01 153.25 3 1800 MILE 3.30 0.08 0.40 0.00 0.64 0.00 6.02 1. <= 10%OAKHURST 1101 OAKHURST 110110090 31.38 1754.73 134.58 4 1800 MILE 11.48 0.08 0.59 0.00 0.20 1.48 17.29 1. <= 10%OREGON TRAIL 1104 OREGON TRAIL 11041574 15.86 629.46 133.27 5 1800 MILE 4.09 0.37 1.27 0.00 1.60 0.00 8.54 1. <= 10%MIDDLETOWN 1101 MIDDLETOWN 1101622 12.05 939.18 129.25 6 1800 MILE 4.28 0.52 0.14 0.00 0.00 0.00 7.00 1. <= 10%BIG BEND 1102 BIG BEND 11021972 21.06 4537.67 122.68 7 1800 MILE 0.23 0.17 0.00 0.00 0.96 0.00 19.71 1. <= 10%DESCHUTES 1104 DESCHUTES 11041370 14.73 481.79 119.37 8 1800 MILE 9.90 0.04 0.40 0.00 0.23 0.00 4.14 1. <= 10%DESCHUTES 1101 DESCHUTES 11011580 45.36 2608.48 115.48 9 1800 MILE 18.74 1.49 1.49 0.00 1.41 1.59 20.63 1. <= 10%HIGGINS 1109 HIGGINS 110950072 50.94 2058.04 109.83 10 1800 MILE 3.91 0.09 2.04 0.40 4.31 0.02 40.17 1. <= 10%DIAMOND SPRINGS 1105 DIAMOND SPRINGS 11057722 47.85 2812.35 108.10 11 1800 MILE 28.23 2.90 3.28 0.00 1.59 0.00 11.85 1. <= 10%OREGON TRAIL 1104 OREGON TRAIL 11041634 17.00 444.45 105.89 12 1800 MILE 5.09 0.62 1.74 0.00 0.47 0.00 9.08 1. <= 10%CHALLENGE 1102 CHALLENGE 11021064 20.30 3727.17 105.13 13 1800 MILE 1.76 0.00 2.17 0.67 3.41 0.05 12.24 1. <= 10%BANGOR 1101 BANGOR 11017446 28.47 4060.54 103.42 14 1800 MILE 18.15 0.61 2.61 0.00 0.00 0.12 6.97 1. <= 10%VACA DIXON 1105 VACA DIXON 110540092 24.46 418.23 102.39 15 1800 MILE 6.07 0.51 0.15 0.03 1.79 0.24 15.67 1. <= 10%MARIPOSA 2102 MARIPOSA 210210880 39.25 901.89 101.36 16 1800 MILE 28.35 0.68 1.10 0.00 0.10 0.22 8.79 1. <= 10%SHINGLE SPRINGS 2109 SHINGLE SPRINGS 210913322 40.40 1742.54 99.59 17 1800 MILE 35.50 0.12 1.06 0.00 0.17 0.15 3.41 1. <= 10%AUBERRY 1101 AUBERRY 1101R2578 42.35 1543.29 99.46 18 1800 MILE 13.63 0.33 1.14 0.00 2.49 0.00 24.76 1. <= 10%WISE 1102 WISE 11022230 23.89 705.05 97.20 19 1800 MILE 17.59 0.05 0.74 0.00 0.19 0.15 5.17 1. <= 10%OREGON TRAIL 1104 OREGON TRAIL 1104circuit_breaker 10.72 659.85 95.23 20 1800 MILE 0.67 0.51 1.36 0.00 0.90 0.00 7.29 1. <= 10%UKIAH 1111 UKIAH 1111534 18.28 1145.63 91.00 21 1800 MILE 7.10 0.50 0.49 0.00 0.54 0.00 9.65 1. <= 10%CEDAR CREEK 1101 CEDAR CREEK 11011664 28.93 2298.21 90.07 22 1800 MILE 6.94 0.04 3.57 0.00 3.94 0.00 14.44 1. <= 10%PUEBLO 2103 PUEBLO 2103678 34.57 3953.46 89.85 23 1800 MILE 7.70 0.67 0.62 0.00 4.59 0.05 20.94 1. <= 10%STILLWATER 1102 STILLWATER 1102circuit_breaker 24.40 1386.84 89.61 24 1800 MILE 12.83 0.28 1.06 0.00 0.19 0.12 9.93 1. <= 10%DIAMOND SPRINGS 1105 DIAMOND SPRINGS 11052102 35.12 1931.38 88.19 25 1800 MILE 0.82 0.04 0.00 0.00 0.00 0.00 34.26 1. <= 10%BRIDGEVILLE 1102 BRIDGEVILLE 1102circuit_breaker 25.27 2534.24 84.19 26 1800 MILE 4.85 0.06 0.10 0.00 0.69 0.00 19.56 1. <= 10%HIGGINS 1109 HIGGINS 1109circuit_breaker 26.34 1247.19 82.50 27 1800 MILE 10.55 0.21 1.29 0.46 2.37 0.00 11.47 1. <= 10%PIKE CITY 1101 PIKE CITY 1101circuit_breaker 19.42 4458.09 80.99 28 1800 MILE 2.96 0.27 0.43 0.05 1.29 0.76 13.65 1. <= 10%GARBERVILLE 1102 GARBERVILLE 110256048 4.84 2568.29 79.70 29 1800 MILE 0.04 0.00 0.00 0.00 0.68 0.00 4.12 1. <= 10%CEDAR CREEK 1101 CEDAR CREEK 11011656 31.31 4190.48 79.01 30 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 31.31 1. <= 10%FITCH MOUNTAIN 1113 FITCH MOUNTAIN 11136751 20.60 3310.72 78.26 31 1800 MILE 1.27 0.24 0.08 0.00 6.16 0.00 12.84 1. <= 10%RED BLUFF 1101 RED BLUFF 11011334 39.97 674.19 77.91 32 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 39.97 1. <= 10%LAYTONVILLE 1102 LAYTONVILLE 1102500 14.71 1702.73 74.61 33 1800 MILE 0.62 0.20 0.00 0.00 0.08 0.00 13.82 1. <= 10%OAKHURST 1103 OAKHURST 1103circuit_breaker 30.21 1548.50 74.36 34 1800 MILE 3.95 0.11 1.30 0.00 0.06 0.14 24.65 1. <= 10%MOUNTAIN QUARRIES 2101 MOUNTAIN QUARRIES 2101circuit_breaker 25.84 918.86 72.73 35 1800 MILE 23.15 0.22 0.13 0.00 0.00 0.00 2.34 1. <= 10%VACAVILLE 1108 VACAVILLE 110838316 16.58 403.82 72.26 36 1800 MILE 12.51 0.00 1.16 0.00 0.18 0.00 2.73 1. <= 10%CEDAR CREEK 1101 CEDAR CREEK 11011608 32.90 2930.85 71.51 37 1800 MILE 3.09 0.12 2.00 0.00 1.59 0.09 26.02 1. <= 10%BELL 1107 BELL 11072400 10.05 800.42 69.05 38 1800 MILE 7.14 0.00 1.51 0.00 0.05 0.07 1.29 1. <= 10%PHILO 1101 PHILO 110137222 24.50 1347.35 68.46 39 1800 MILE 0.00 0.00 0.00 0.00 1.47 0.00 23.02 1. <= 10%SAN JOAQUIN NO2 1103 SAN JOAQUIN #2 1103circuit_breaker 67.31 1543.75 67.24 40 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 67.31 1. <= 10%SALMON CREEK 1101 SALMON CREEK 110188998 7.63 523.07 66.34 41 1800 MILE 4.83 0.07 0.05 0.00 0.34 0.00 2.35 1. <= 10%FRUITLAND 1142 FRUITLAND 114293234 10.69 1938.31 66.00 42 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 10.69 1. <= 10%DESCHUTES 1104 DESCHUTES 110449024 16.03 274.04 65.93 43 1800 MILE 11.19 0.10 0.97 0.00 0.32 0.14 3.31 1. <= 10%AUBERRY 1102 AUBERRY 1102circuit_breaker 33.25 517.33 65.71 44 1800 MILE 1.50 0.00 0.00 0.00 0.06 0.00 31.69 1. <= 10%STILLWATER 1102 STILLWATER 110248952 10.65 501.33 64.19 45 1800 MILE 5.07 0.08 0.77 0.00 0.05 0.00 4.68 1. <= 10%OAKHURST 1103 OAKHURST 110363334 15.27 534.46 63.94 46 1800 MILE 4.45 0.26 2.31 0.00 0.48 0.21 7.55 1. <= 10%BELL 1108 BELL 11082202 29.43 891.93 63.87 47 1800 MILE 14.99 1.33 1.06 0.00 0.31 0.00 11.74 1. <= 10%WYANDOTTE 1109 WYANDOTTE 110979932 21.15 630.61 63.48 48 1800 MILE 8.05 0.45 0.00 0.57 1.69 0.00 10.38 1. <= 10%WILLITS 1103 WILLITS 110391810 27.13 3745.77 62.65 49 1800 MILE 5.12 0.00 2.46 0.00 2.50 0.00 17.06 1. <= 10%GEYSERVILLE 1101 GEYSERVILLE 1101166 11.13 1016.10 62.20 50 1800 MILE 2.41 0.25 0.30 0.00 0.48 0.00 7.79 1. <= 10%WOODSIDE 1101 WOODSIDE 11018974 11.55 4187.53 62.16 51 1800 MILE 1.36 0.05 2.82 0.03 4.09 0.12 3.09 1. <= 10%SILVERADO 2104 SILVERADO 2104632 7.59 742.09 61.81 52 1800 MILE 1.66 0.17 0.87 0.00 0.31 0.00 4.59 1. <= 10%MARIPOSA 2102 MARIPOSA 210237282 52.14 1212.93 60.81 53 1800 MILE 9.95 0.71 1.92 0.00 0.08 0.23 39.23 1. <= 10%DESCHUTES 1104 DESCHUTES 11049718 20.59 421.88 60.54 54 1800 MILE 0.34 0.00 0.00 0.00 0.00 0.00 20.25 1. <= 10%OAKHURST 1101 OAKHURST 11015490 10.50 497.19 59.47 55 1800 MILE 7.80 0.15 0.44 0.00 0.10 0.18 1.68 1. <= 10%COTTONWOOD 1101 COTTONWOOD 110168190 23.87 602.76 58.36 56 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 23.87 1. <= 10%PHILO 1101 PHILO 1101circuit_breaker 32.49 2622.59 57.81 57 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 32.49 1. <= 10%STILLWATER 1102 STILLWATER 11021644 22.77 905.98 56.90 58 1800 MILE 11.89 0.62 0.24 0.00 1.29 1.04 7.69 1. <= 10%COARSEGOLD 2103 COARSEGOLD 210310820 27.60 467.82 56.49 59 1800 MILE 12.39 0.64 0.38 0.00 0.30 0.08 13.81 1. <= 10%APPLE HILL 2102 APPLE HILL 21021532 37.07 3569.71 56.04 60 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 37.07 1. <= 10%GIRVAN 1101 GIRVAN 1101323094 35.31 1389.31 55.66 61 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 35.31 1. <= 10%LAYTONVILLE 1102 LAYTONVILLE 1102572 20.62 2694.95 55.53 62 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 20.62 1. <= 10%PIKE CITY 1102 PIKE CITY 1102circuit_breaker 9.42 2708.54 55.33 63 1800 MILE 0.11 0.16 0.00 0.00 0.16 0.09 8.89 1. <= 10%BROWNS VALLEY 1101 BROWNS VALLEY 110193870 20.83 564.97 55.08 64 1800 MILE 12.13 0.58 0.10 0.00 0.03 0.00 7.99 1. <= 10%ANTLER 1101 ANTLER 11011378 24.27 2949.37 54.01 65 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 24.27 1. <= 10%CHALLENGE 1102 CHALLENGE 1102circuit_breaker 14.67 3651.32 53.45 66 1800 MILE 0.23 0.12 0.26 0.05 2.42 0.12 11.47 1. <= 10%LAYTONVILLE 1102 LAYTONVILLE 110237586 13.88 1272.33 52.81 67 1800 MILE 0.09 0.00 0.00 0.00 0.06 0.00 13.73 1. <= 10%HOOPA 1101 HOOPA 11013290 12.86 1552.94 52.56 68 1800 MILE 0.30 0.15 0.11 0.00 2.71 0.04 9.54 1. <= 10%PENRYN 1105 PENRYN 11051342 22.49 877.49 52.37 69 1800 MILE 0.42 0.20 0.05 0.00 0.93 0.00 20.90 1. <= 10%KANAKA 1101 KANAKA 110165606 12.84 3194.72 51.40 70 1800 MILE 0.08 0.00 0.00 0.00 0.00 0.00 12.76 1. <= 10%LINCOLN 1104 LINCOLN 11042070 20.61 602.85 50.50 71 1800 MILE 11.64 0.77 1.05 0.00 0.30 0.00 6.85 1. <= 10%WYANDOTTE 1103 WYANDOTTE 11031974 23.01 4221.08 49.63 72 1800 MILE 0.17 0.00 0.00 0.00 0.96 0.00 21.87 1. <= 10%COTTONWOOD 1102 COTTONWOOD 11021578 29.49 1137.09 49.54 73 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 29.49 1. <= 10%PENRYN 1103 PENRYN 11032198 16.81 594.74 48.91 74 1800 MILE 4.56 0.20 0.58 0.00 0.78 0.00 10.70 1. <= 10%LAS GALLINAS A 1105 LAS GALLINAS A 110599904 5.44 739.24 48.84 75 1800 MILE 0.20 0.00 0.00 0.00 0.90 0.00 4.34 1. <= 10%PLACERVILLE 2106 PLACERVILLE 21067522 65.19 6799.49 48.76 76 1800 MILE 0.09 0.01 0.35 0.00 0.60 0.00 64.14 1. <= 10%DESCHUTES 1104 DESCHUTES 11049726 14.64 255.19 48.68 77 2400 MILE 11.27 0.01 0.37 0.00 0.10 0.00 2.89 1. <= 10%GRASS VALLEY 1103 GRASS VALLEY 11032180 44.19 2408.35 48.35 78 2400 MILE 3.94 0.57 0.12 0.12 2.64 0.00 36.80 1. <= 10%HIGGINS 1109 HIGGINS 110950078 46.97 844.79 47.47 79 2400 MILE 12.58 0.61 0.10 0.26 0.50 0.00 32.92 1. <= 10%HOOPA 1101 HOOPA 11013174 17.96 2544.24 47.27 80 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 17.96 1. <= 10%

AtchE-1 APP3-69

Circuit Name Circuit Protection Zone Remaining EVM Miles Forecasted Tree Work Tree Weighted Risk Score Tree Weighted Rank Plan (Mile Cutoff)Miles Complete and Verified as

of 6/30/21(Audited)



(Unaudited)


Miles Constrained Environmental Holds

(Unaudited)

Miles Constrained Other (Unaudited)

Remaining Miles (Unaudited)

Risk Milesby Percentage(Top 20%)

SHINGLE SPRINGS 2109 SHINGLE SPRINGS 21099372 18.60 589.09 47.13 81 2400 MILE 0.84 0.00 0.00 0.00 0.03 0.00 17.74 1. <= 10%COTTONWOOD 1101 COTTONWOOD 11011610 36.98 1026.81 47.08 82 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 36.98 1. <= 10%DESCHUTES 1104 DESCHUTES 1104circuit_breaker 12.88 274.71 47.06 83 2400 MILE 9.84 0.00 0.43 0.00 0.29 0.00 2.32 1. <= 10%NARROWS 2101 NARROWS 21011202 45.52 1236.96 46.92 84 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 45.52 1. <= 10%GARBERVILLE 1102 GARBERVILLE 11024744 17.05 1491.09 46.69 85 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 17.05 1. <= 10%ZACA 1102 ZACA 1102Y54 31.63 421.35 46.13 86 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 31.63 1. <= 10%CALISTOGA 1101 CALISTOGA 1101734 6.58 851.52 45.87 87 2400 MILE 0.01 0.00 0.76 0.00 0.75 0.12 4.94 1. <= 10%DESCHUTES 1101 DESCHUTES 11011380 17.28 492.84 45.46 88 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 17.28 1. <= 10%MARIPOSA 2102 MARIPOSA 21029590 35.79 1638.67 45.03 89 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 35.79 1. <= 10%FRUITLAND 1142 FRUITLAND 114263170 11.76 2045.73 44.77 90 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 11.76 1. <= 10%WISE 1102 WISE 11022054 13.39 354.51 44.54 91 2400 MILE 0.32 0.00 0.00 0.00 0.00 0.00 13.07 1. <= 10%SHINGLE SPRINGS 2110 SHINGLE SPRINGS 21107742 45.20 2517.81 43.79 92 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 45.20 1. <= 10%SAND CREEK 1103 SAND CREEK 110345190 36.37 653.37 43.65 93 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 36.37 1. <= 10%DIAMOND SPRINGS 1105 DIAMOND SPRINGS 110519910 19.31 547.20 43.15 94 2400 MILE 0.48 0.00 0.00 0.00 0.00 0.00 18.83 1. <= 10%ELK CREEK 1101 ELK CREEK 11012106 13.25 418.97 42.98 95 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 13.25 1. <= 10%DOBBINS 1101 DOBBINS 11011264 35.61 3459.03 42.85 96 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 35.61 1. <= 10%GIRVAN 1101 GIRVAN 11011330 30.57 1827.81 42.57 97 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 30.57 1. <= 10%VOLTA 1101 VOLTA 110180454 32.11 2042.39 42.57 98 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 32.11 1. <= 10%TIVY VALLEY 1107 TIVY VALLEY 1107R1817 14.59 813.34 42.38 99 2400 MILE 9.16 0.30 0.58 0.00 0.21 0.00 4.21 1. <= 10%AUBERRY 1102 AUBERRY 1102R2850 26.34 405.00 42.15 100 2400 MILE 0.00 0.00 0.00 0.00 0.15 0.00 26.19 1. <= 10%BELL 1107 BELL 110750172 5.45 377.12 41.29 103 2400 MILE 3.77 0.36 0.55 0.00 0.00 0.00 0.78 1. <= 10%SILVERADO 2104 SILVERADO 210478268 6.20 692.14 18.92 243 2400 MILE 1.11 0.13 0.93 0.00 0.16 0.00 3.88 1. <= 10%SAN LUIS OBISPO 1107 SAN LUIS OBISPO 1107V60 15.52 654.60 4.49 650 2400 MILE 3.84 0.21 0.11 0.00 1.04 0.25 10.07 3. >20 ‐ 30%WISHON 1101 WISHON 1101circuit_breaker 5.31 317.00 2.47 827 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 5.31 3. >20 ‐ 30%

Total 2522.19 173408.40 7215.03 512.39 22.17 59.18 2.63 85.21 7.97 1832.10

Note: “As part of EVM’s process, a circuit segment categorized as completed (work verified), may revert to an in‐progress status if a new vegetation point (tree) is associated with a circuit segment after the work verification was completed. If this were to occur, miles associated with this circuit segment will not be recognized as complete until work verification has been re‐performed. This condition could cause progress which was recognized in one quarter to not be recognized in a subsequent quarter.”

AtchE-2 APP3-70


ATTACHMENT J

UPDATED VERIFICATION OF SUMEET SINGH

APP3-71

Verification of Sumeet Singh

1. I, Sumeet Singh, am submitting this verification as a part of Pacific Gas andElectric Company’s (PG&E) 90-Day Report submitted on August 4, 2021 (August Report). Below, I address the Elements of the August Report that require an officer verification.

2. I am currently employed by PG&E as a Senior Vice President and the ChiefRisk Officer. I make this verification based on my own personal knowledge and/or based on information provided to me by other PG&E employees who have responsibility over the specific areas identified or responsibility for verifying and validating information. Where I am relying on information provided by other PG&E employees, I state that my understanding is based on information and belief.

3. Element 9 requires a “verification by a senior officer of PG&E that the riskmodel, including underlying data sets and vegetation management records, it is using to prioritize [Enhanced Vegetation Management (EVM)] is as set forth in its report.” I provided a verification for Element 9 with the Corrective Action Plan submitted on May 6, 2021. As indicated in Element 7 of the August Report, “[w]e did not make in the past 90 days and do not plan on making in the next 90 days any changes to the 2021 Wildfire Distribution Risk Model, Wildfire Consequence Model, or Vegetation Risk Model for purposes of the 2021 EVM Scope of Work or informing EVM work in 2021.”

4. Element 10 requires a “verification by a senior officer of PG&E that it willtarget a substantial majority of EVM to the highest risk circuit protection zones first, as shown by its risk model or other ranking, in the next 90 days for EVM.” In the next 90 days, PG&E will use the 2021 EVM Scope of Work described and included in the August Report to perform EVM work. As explained in Elements 2-4 of the Corrective Action Plan, the 2021 EVM Scope of Work utilizes a risk-ranked list of Circuit Protection Zones (CPZs) to prioritize the highest risk CPZs and perform work on these CPZs using the 1-n risk ranking approach described in Element 3(a). The 2021 EVM Scope of Work can be modified by the Wildfire Risk Governance Steering Committee (WRGSC) to account for external circumstances such as delays in the permitting process, customer refusals, and changes in work resulting from wildfires that have required us to modify our workplans. In addition, EVM work will also be performed in 2021 related to commitments and permitting, as described in Element 6 of the August Report.

5. Element 11 requires a “verification by a senior officer of PG&E that ittargeted a substantial majority of EVM to the highest risk circuit protection zones first, as shown by its risk model or other ranking, in the prior 90 days.” In the prior 90 days, PG&E targeted EVM work based on the 2021 EVM Scope of Work. The EVM work that has been performed through June 30, 2021 is reflected in Attachment E to the August Report. The information in Attachment E was provided by our Vegetation Management team. In addition, some of the information in Attachment E has been reviewed by our

APP3-72

Internal Audit organization. The information that Internal Audit has reviewed is designated as “audited.”

6. Element 12 requires a “verification by a senior officer of PG&E that the company has communicated information and internal decisions in items 3, 4 and 9 above to personnel of PG&E’s EVM programs and that such personnel is aware of where to target EVM in the subsequent 90 days.” On information and belief, Element 5(b) in the August Report describes the communications that PG&E has had with EVM personnel and contractors regarding EVM work in 2021, as well as plans for ongoing communications.

I verify that the statements above are true and correct to the best of my knowledge or, where indicated, on information and belief. This verification was executed in San Ramon, California on August 4, 2021.

_____________________________________ Sumeet Singh Pacific Gas and Electric Company Senior Vice President and Chief Risk Officer

APP3-73


ATTACHMENT K

GIS DATA FOR 2021 ENHANCED VEGETATION MANAGEMENT

SCOPE OF WORK (PROVIDED IN A SEPARATE ZIP FILE)

(UNAUDITED)

APP3-74


ATTACHMENT L

ENHANCED VEGETATION MANAGEMENT WORK TO BE

PERFORMED IN NEXT 90 DAYS

APP3-75

Circuit Name Circuit Protection ZoneRemaining EVM Miles

Forecasted Tree Work

Tree Weighted Risk Score

Tree Weighted Rank Plan (Mile Cutoff)

Miles Complete and Verified 07/01/21 ‐

07/18/21 (Unaudited)



(Unaudited)


Miles Constrained Environmental

Holds (Unaudited)

Miles Constrained Other

(Unaudited)Remaining Miles (Unaudited)

Risk Miles by Percentage (Top 20%)

RIO DELL 1102 RIO DELL 11024230 22.82 4236.60 202.04 1 1800 MILE 0.23 0.19 0.84 0.00 13.25 0.00 8.31 1. <= 10%APPLE HILL 2102 APPLE HILL 2102circuit_breaker 38.41 4581.57 175.16 2 1800 MILE 4.66 0.82 4.13 0.00 3.57 0.00 25.23 1. <= 10%FORT SEWARD 1121 FORT SEWARD 11211690 10.43 1715.01 153.25 3 1800 MILE 0.39 0.55 0.86 0.00 1.56 0.00 7.06 1. <= 10%OAKHURST 1101 OAKHURST 110110090 31.38 1754.73 134.58 4 1800 MILE 0.23 0.00 0.62 0.00 0.25 0.00 30.28 1. <= 10%OREGON TRAIL 1104 OREGON TRAIL 11041574 15.86 629.46 133.27 5 1800 MILE 2.19 0.00 1.46 0.00 2.06 0.00 10.15 1. <= 10%MIDDLETOWN 1101 MIDDLETOWN 1101622 12.05 939.18 129.25 6 1800 MILE 0.82 0.99 0.34 0.00 1.58 0.03 8.28 1. <= 10%BIG BEND 1102 BIG BEND 11021972 21.06 4537.67 122.68 7 1800 MILE 0.17 0.00 0.00 0.11 1.25 0.00 19.53 1. <= 10%DESCHUTES 1104 DESCHUTES 11041370 14.73 481.79 119.37 8 1800 MILE 0.58 0.00 0.59 0.00 0.27 0.00 13.28 1. <= 10%DESCHUTES 1101 DESCHUTES 11011580 45.36 2608.48 115.48 9 1800 MILE 4.92 0.22 3.63 0.00 1.55 0.00 35.03 1. <= 10%HIGGINS 1109 HIGGINS 110950072 50.94 2058.04 109.83 10 1800 MILE 0.99 0.23 2.63 0.51 5.08 0.00 41.50 1. <= 10%DIAMOND SPRINGS 1105 DIAMOND SPRINGS 11057722 47.85 2812.35 108.10 11 1800 MILE 7.08 1.41 6.09 0.00 2.34 0.00 30.93 1. <= 10%OREGON TRAIL 1104 OREGON TRAIL 11041634 17.00 444.45 105.89 12 1800 MILE 4.03 0.00 2.13 0.00 2.22 0.00 8.62 1. <= 10%CHALLENGE 1102 CHALLENGE 11021064 20.30 3727.17 105.13 13 1800 MILE 0.05 0.00 2.24 0.82 3.51 0.05 13.63 1. <= 10%BANGOR 1101 BANGOR 11017446 28.47 4060.54 103.42 14 1800 MILE 1.31 0.19 2.72 0.00 0.26 0.08 23.91 1. <= 10%VACA DIXON 1105 VACA DIXON 110540092 24.46 418.23 102.39 15 1800 MILE 2.62 0.00 1.72 0.94 2.73 0.00 16.45 1. <= 10%MARIPOSA 2102 MARIPOSA 210210880 39.25 901.89 101.36 16 1800 MILE 2.12 0.07 1.38 0.00 0.23 0.00 35.44 1. <= 10%SHINGLE SPRINGS 2109 SHINGLE SPRINGS 210913322 40.40 1742.54 99.59 17 1800 MILE 0.24 0.04 1.09 0.00 0.21 0.00 38.81 1. <= 10%AUBERRY 1101 AUBERRY 1101R2578 42.35 1543.29 99.46 18 1800 MILE 2.05 0.08 1.39 0.00 4.14 0.04 34.64 1. <= 10%WISE 1102 WISE 11022230 23.89 705.05 97.20 19 1800 MILE 0.30 0.00 0.74 0.00 0.32 0.00 22.52 1. <= 10%OREGON TRAIL 1104 OREGON TRAIL 1104circuit_breaker 10.72 659.85 95.23 20 1800 MILE 1.01 0.19 2.26 0.00 2.50 0.00 4.76 1. <= 10%UKIAH 1111 UKIAH 1111534 18.28 1145.63 91.00 21 1800 MILE 0.18 0.71 0.80 0.00 0.59 0.00 16.00 1. <= 10%CEDAR CREEK 1101 CEDAR CREEK 11011664 28.93 2298.21 90.07 22 1800 MILE 0.51 0.00 6.91 0.00 5.11 0.00 16.40 1. <= 10%PUEBLO 2103 PUEBLO 2103678 34.57 3953.46 89.85 23 1800 MILE 1.61 1.02 1.51 0.00 7.14 0.00 23.29 1. <= 10%STILLWATER 1102 STILLWATER 1102circuit_breaker 24.40 1386.84 89.61 24 1800 MILE 1.96 0.08 1.23 0.00 0.19 0.00 20.94 1. <= 10%DIAMOND SPRINGS 1105 DIAMOND SPRINGS 11052102 35.12 1931.38 88.19 25 1800 MILE ‐0.02 0.00 0.00 0.00 0.00 0.00 35.13 1. <= 10%BRIDGEVILLE 1102 BRIDGEVILLE 1102circuit_breaker 25.27 2534.24 84.19 26 1800 MILE 0.62 0.16 0.10 0.00 0.98 0.00 23.40 1. <= 10%HIGGINS 1109 HIGGINS 1109circuit_breaker 26.34 1247.19 82.50 27 1800 MILE 1.51 0.29 1.46 0.46 2.47 0.00 20.15 1. <= 10%PIKE CITY 1101 PIKE CITY 1101circuit_breaker 19.42 4458.09 80.99 28 1800 MILE 0.64 0.06 0.87 0.15 1.86 0.00 15.83 1. <= 10%GARBERVILLE 1102 GARBERVILLE 110256048 4.84 2568.29 79.70 29 1800 MILE 0.00 0.00 0.00 0.00 1.62 0.06 3.16 1. <= 10%CEDAR CREEK 1101 CEDAR CREEK 11011656 31.31 4190.48 79.01 30 1800 MILE 0.00 0.00 0.02 0.00 0.00 0.00 31.28 1. <= 10%FITCH MOUNTAIN 1113 FITCH MOUNTAIN 11136751 20.60 3310.72 78.26 31 1800 MILE 0.00 0.63 1.95 0.00 9.52 0.23 8.26 1. <= 10%RED BLUFF 1101 RED BLUFF 11011334 39.97 674.19 77.91 32 1800 MILE 3.09 0.00 0.91 0.00 0.63 0.00 35.34 1. <= 10%LAYTONVILLE 1102 LAYTONVILLE 1102500 14.71 1702.73 74.61 33 1800 MILE 0.98 0.17 0.52 0.00 4.04 0.00 9.01 1. <= 10%OAKHURST 1103 OAKHURST 1103circuit_breaker 30.21 1548.50 74.36 34 1800 MILE 1.46 0.03 2.43 0.00 0.26 0.00 26.03 1. <= 10%MOUNTAIN QUARRIES 2101 MOUNTAIN QUARRIES 2101circuit_breaker 25.84 918.86 72.73 35 1800 MILE 0.16 0.00 0.13 0.00 0.00 0.00 25.54 1. <= 10%VACAVILLE 1108 VACAVILLE 110838316 16.58 403.82 72.26 36 1800 MILE 0.41 0.00 1.22 0.27 0.37 0.00 14.32 1. <= 10%CEDAR CREEK 1101 CEDAR CREEK 11011608 32.90 2930.85 71.51 37 1800 MILE 0.64 0.00 3.67 0.00 3.13 0.00 25.45 1. <= 10%BELL 1107 BELL 11072400 10.05 800.42 69.05 38 1800 MILE 0.05 0.06 1.56 0.00 0.05 0.00 8.33 1. <= 10%PHILO 1101 PHILO 110137222 24.50 1347.35 68.46 39 1800 MILE 0.00 0.00 0.00 0.00 1.47 0.00 23.02 1. <= 10%SAN JOAQUIN NO2 1103 SAN JOAQUIN #2 1103circuit_breaker 67.31 1543.75 67.24 40 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 67.31 1. <= 10%SALMON CREEK 1101 SALMON CREEK 110188998 7.63 523.07 66.34 41 1800 MILE 0.28 0.20 0.05 0.00 0.80 0.00 6.31 1. <= 10%FRUITLAND 1142 FRUITLAND 114293234 10.69 1938.31 66.00 42 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 10.69 1. <= 10%DESCHUTES 1104 DESCHUTES 110449024 16.03 274.04 65.93 43 1800 MILE 0.74 0.00 0.97 0.00 0.32 0.00 14.01 1. <= 10%AUBERRY 1102 AUBERRY 1102circuit_breaker 33.25 517.33 65.71 44 1800 MILE 0.00 0.00 0.00 0.00 0.06 0.00 33.19 1. <= 10%STILLWATER 1102 STILLWATER 110248952 10.65 501.33 64.19 45 1800 MILE 0.35 0.05 0.83 0.00 0.05 0.00 9.37 1. <= 10%OAKHURST 1103 OAKHURST 110363334 15.27 534.46 63.94 46 1800 MILE 0.94 0.00 2.88 0.00 0.70 0.00 10.75 1. <= 10%BELL 1108 BELL 11082202 29.43 891.93 63.87 47 1800 MILE 3.40 0.90 1.22 0.00 0.46 0.00 23.45 1. <= 10%WYANDOTTE 1109 WYANDOTTE 110979932 21.15 630.61 63.48 48 1800 MILE 2.08 0.60 0.00 0.62 2.08 0.00 15.77 1. <= 10%WILLITS 1103 WILLITS 110391810 27.13 3745.77 62.65 49 1800 MILE 0.05 0.17 2.64 0.00 2.79 0.00 21.49 1. <= 10%GEYSERVILLE 1101 GEYSERVILLE 1101166 11.13 1016.10 62.20 50 1800 MILE 0.76 1.58 0.30 0.00 1.40 0.00 7.09 1. <= 10%WOODSIDE 1101 WOODSIDE 11018974 11.55 4187.53 62.16 51 1800 MILE 0.11 0.59 3.10 0.03 4.39 0.07 3.26 1. <= 10%SILVERADO 2104 SILVERADO 2104632 7.59 742.09 61.81 52 1800 MILE 0.06 0.41 0.87 0.00 0.36 0.00 5.90 1. <= 10%MARIPOSA 2102 MARIPOSA 210237282 52.14 1212.93 60.81 53 1800 MILE 1.17 0.09 2.77 0.00 0.08 0.00 48.03 1. <= 10%DESCHUTES 1104 DESCHUTES 11049718 20.59 421.88 60.54 54 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 20.59 1. <= 10%OAKHURST 1101 OAKHURST 11015490 10.50 497.19 59.47 55 1800 MILE 0.09 0.00 0.51 0.00 0.14 0.00 9.76 1. <= 10%COTTONWOOD 1101 COTTONWOOD 110168190 23.87 602.76 58.36 56 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 23.87 1. <= 10%PHILO 1101 PHILO 1101circuit_breaker 32.49 2622.59 57.81 57 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 32.49 1. <= 10%STILLWATER 1102 STILLWATER 11021644 22.77 905.98 56.90 58 1800 MILE 3.43 0.05 0.35 0.04 1.29 0.03 17.59 1. <= 10%COARSEGOLD 2103 COARSEGOLD 210310820 27.60 467.82 56.49 59 1800 MILE 5.69 0.53 0.98 0.00 0.90 0.00 19.49 1. <= 10%APPLE HILL 2102 APPLE HILL 21021532 37.07 3569.71 56.04 60 1800 MILE 0.03 0.00 0.17 0.00 0.04 0.00 36.84 1. <= 10%GIRVAN 1101 GIRVAN 1101323094 35.31 1389.31 55.66 61 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 35.31 1. <= 10%LAYTONVILLE 1102 LAYTONVILLE 1102572 20.62 2694.95 55.53 62 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 20.62 1. <= 10%PIKE CITY 1102 PIKE CITY 1102circuit_breaker 9.42 2708.54 55.33 63 1800 MILE 0.37 0.00 0.00 0.00 1.33 0.00 7.71 1. <= 10%BROWNS VALLEY 1101 BROWNS VALLEY 110193870 20.83 564.97 55.08 64 1800 MILE 2.55 0.35 0.12 0.00 0.13 0.00 17.69 1. <= 10%ANTLER 1101 ANTLER 11011378 24.27 2949.37 54.01 65 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 24.27 1. <= 10%CHALLENGE 1102 CHALLENGE 1102circuit_breaker 14.67 3651.32 53.45 66 1800 MILE 0.10 0.05 0.37 0.68 4.33 0.04 9.09 1. <= 10%LAYTONVILLE 1102 LAYTONVILLE 110237586 13.88 1272.33 52.81 67 1800 MILE 0.00 0.00 0.00 0.00 0.06 0.00 13.82 1. <= 10%HOOPA 1101 HOOPA 11013290 12.86 1552.94 52.56 68 1800 MILE 0.25 0.08 0.23 0.00 4.33 0.00 7.96 1. <= 10%PENRYN 1105 PENRYN 11051342 22.49 877.49 52.37 69 1800 MILE 2.32 0.22 1.29 0.00 4.45 0.00 14.22 1. <= 10%KANAKA 1101 KANAKA 110165606 12.84 3194.72 51.40 70 1800 MILE 0.18 0.01 0.37 0.08 1.78 0.00 10.43 1. <= 10%LINCOLN 1104 LINCOLN 11042070 20.61 602.85 50.50 71 1800 MILE 1.43 0.31 1.14 0.00 0.93 0.00 16.81 1. <= 10%WYANDOTTE 1103 WYANDOTTE 11031974 23.01 4221.08 49.63 72 1800 MILE 0.00 0.00 0.01 0.00 1.21 0.00 21.79 1. <= 10%COTTONWOOD 1102 COTTONWOOD 11021578 29.49 1137.09 49.54 73 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 29.49 1. <= 10%PENRYN 1103 PENRYN 11032198 16.81 594.74 48.91 74 1800 MILE 1.56 0.25 0.68 0.00 2.46 0.00 11.87 1. <= 10%LAS GALLINAS A 1105 LAS GALLINAS A 110599904 5.44 739.24 48.84 75 1800 MILE 0.45 0.20 0.00 0.00 0.96 0.00 3.83 1. <= 10%PLACERVILLE 2106 PLACERVILLE 21067522 65.19 6799.49 48.76 76 1800 MILE 1.66 0.12 3.09 0.00 4.33 0.00 55.98 1. <= 10%DESCHUTES 1104 DESCHUTES 11049726 14.64 255.19 48.68 77 2400 MILE 0.26 0.08 0.48 0.00 0.10 0.00 13.72 1. <= 10%GRASS VALLEY 1103 GRASS VALLEY 11032180 44.19 2408.35 48.35 78 2400 MILE 2.78 0.98 0.71 0.26 4.22 0.00 35.23 1. <= 10%HIGGINS 1109 HIGGINS 110950078 46.97 844.79 47.47 79 2400 MILE 5.96 0.59 0.10 0.26 0.50 0.00 39.56 1. <= 10%HOOPA 1101 HOOPA 11013174 17.96 2544.24 47.27 80 2400 MILE 0.33 0.00 0.00 0.00 0.35 0.00 17.28 1. <= 10%SHINGLE SPRINGS 2109 SHINGLE SPRINGS 21099372 18.60 589.09 47.13 81 2400 MILE 0.00 0.00 0.00 0.00 0.03 0.00 18.57 1. <= 10%COTTONWOOD 1101 COTTONWOOD 11011610 36.98 1026.81 47.08 82 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 36.98 1. <= 10%DESCHUTES 1104 DESCHUTES 1104circuit_breaker 12.88 274.71 47.06 83 2400 MILE 0.38 0.00 0.47 0.00 0.39 0.00 11.64 1. <= 10%NARROWS 2101 NARROWS 21011202 45.52 1236.96 46.92 84 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 45.52 1. <= 10%GARBERVILLE 1102 GARBERVILLE 11024744 17.05 1491.09 46.69 85 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 17.05 1. <= 10%ZACA 1102 ZACA 1102Y54 31.63 421.35 46.13 86 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 31.63 1. <= 10%CALISTOGA 1101 CALISTOGA 1101734 6.58 851.52 45.87 87 2400 MILE 0.00 0.00 0.76 0.00 0.75 0.06 5.01 1. <= 10%DESCHUTES 1101 DESCHUTES 11011380 17.28 492.84 45.46 88 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 17.28 1. <= 10%MARIPOSA 2102 MARIPOSA 21029590 35.79 1638.67 45.03 89 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 35.79 1. <= 10%FRUITLAND 1142 FRUITLAND 114263170 11.76 2045.73 44.77 90 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 11.76 1. <= 10%WISE 1102 WISE 11022054 13.39 354.51 44.54 91 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 13.39 1. <= 10%SHINGLE SPRINGS 2110 SHINGLE SPRINGS 21107742 45.20 2517.81 43.79 92 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 45.20 1. <= 10%SAND CREEK 1103 SAND CREEK 110345190 36.37 653.37 43.65 93 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 36.37 1. <= 10%DIAMOND SPRINGS 1105 DIAMOND SPRINGS 110519910 19.31 547.20 43.15 94 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 19.31 1. <= 10%ELK CREEK 1101 ELK CREEK 11012106 13.25 418.97 42.98 95 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 13.25 1. <= 10%DOBBINS 1101 DOBBINS 11011264 35.61 3459.03 42.85 96 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 35.61 1. <= 10%GIRVAN 1101 GIRVAN 11011330 30.57 1827.81 42.57 97 1800 MILE 0.00 0.00 0.00 0.00 0.00 0.00 30.57 1. <= 10%VOLTA 1101 VOLTA 110180454 32.11 2042.39 42.57 98 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 32.11 1. <= 10%TIVY VALLEY 1107 TIVY VALLEY 1107R1817 14.59 813.34 42.38 99 2400 MILE 1.31 0.00 0.58 0.00 0.21 0.00 12.49 1. <= 10%AUBERRY 1102 AUBERRY 1102R2850 26.34 405.00 42.15 100 2400 MILE 0.00 0.00 0.00 0.00 0.15 0.00 26.19 1. <= 10%BELL 1107 BELL 110750172 5.45 377.12 41.29 103 2400 MILE 0.00 0.52 0.00 0.00 0.00 0.00 4.93 1. <= 10%SILVERADO 2104 SILVERADO 210478268 6.20 692.14 18.92 243 2400 MILE 0.00 0.13 0.00 0.00 0.00 0.00 6.07 1. <= 10%SAN LUIS OBISPO 1107 SAN LUIS OBISPO 1107V60 15.52 654.60 4.49 650 2400 MILE 0.00 0.45 0.55 0.00 0.00 0.00 14.52 3. >20 ‐ 30%WISHON 1101 WISHON 1101circuit_breaker 5.31 317.00 2.47 827 2400 MILE 0.00 0.00 0.00 0.00 0.00 0.00 5.31 3. >20 ‐ 30%

Total 2522.19 173408.40 7215.03 90.87 17.72 90.74 5.21 137.19 0.71 2179.75

Note: “As part of EVM’s process, a circuit segment categorized as completed (work verified), may revert to an in‐progress status if a new vegetation point (tree) is associated with a circuit segment after the work verification was completed. If this were to occur, miles associated with this circuit segmewill not be recognized as complete until work verification has been re‐performed. This condition could cause progress which was recognized in one quarter to not be recognized in a subsequent quarter.”

AtchL-1 APP3-76





Miles Complete and Verified (Actual) as of

6/30/21 (Audited)

Miles Complete and Verified (Actual)

07/01/21 ‐ 07/18/21 (Unaudited)

Miles Complete and Verified (Forecasted) 07/19/21 ‐ 08/06/21

(Unaudited)

Miles Complete and Verified (Actual +

Forecasted) as of 08/06/21 (Unaudited)

Remaining Miles

(Unaudited)


RIO DELL 1102 RIO DELL 11024230 22.82 4236.60 202.04 1 1800 MILE 1.71 0.23 2.40 4.33 18.49 1. <= 10%APPLE HILL 2102 APPLE HILL 2102circuit_breaker 38.41 4581.57 175.16 2 1800 MILE 4.04 4.66 6.64 15.34 23.07 1. <= 10%FORT SEWARD 1121 FORT SEWARD 11211690 10.43 1715.01 153.25 3 1800 MILE 3.30 0.39 1.94 5.63 4.80 1. <= 10%OAKHURST 1101 OAKHURST 110110090 31.38 1754.73 134.58 4 1800 MILE 11.48 0.23 3.38 15.36 16.02 1. <= 10%OREGON TRAIL 1104 OREGON TRAIL 11041574 15.86 629.46 133.27 5 1800 MILE 4.09 2.19 4.93 11.21 4.65 1. <= 10%MIDDLETOWN 1101 MIDDLETOWN 1101622 12.05 939.18 129.25 6 1800 MILE 4.28 0.82 1.42 6.62 5.43 1. <= 10%BIG BEND 1102 BIG BEND 11021972 21.06 4537.67 122.68 7 1800 MILE 0.23 0.17 0.00 0.40 20.66 1. <= 10%DESCHUTES 1104 DESCHUTES 11041370 14.73 481.79 119.37 8 1800 MILE 9.90 0.58 0.00 10.48 4.24 1. <= 10%DESCHUTES 1101 DESCHUTES 11011580 45.36 2608.48 115.48 9 1800 MILE 18.74 4.92 8.29 31.96 13.40 1. <= 10%HIGGINS 1109 HIGGINS 110950072 50.94 2058.04 109.83 10 1800 MILE 3.91 0.99 7.51 12.41 38.53 1. <= 10%DIAMOND SPRINGS 1105 DIAMOND SPRINGS 11057722 47.85 2812.35 108.10 11 1800 MILE 28.23 7.08 10.36 45.67 2.18 1. <= 10%OREGON TRAIL 1104 OREGON TRAIL 11041634 17.00 444.45 105.89 12 1800 MILE 5.09 4.03 3.73 12.85 4.15 1. <= 10%CHALLENGE 1102 CHALLENGE 11021064 20.30 3727.17 105.13 13 1800 MILE 1.76 0.05 1.94 3.74 16.56 1. <= 10%BANGOR 1101 BANGOR 11017446 28.47 4060.54 103.42 14 1800 MILE 18.15 1.31 4.03 23.48 4.98 1. <= 10%VACA DIXON 1105 VACA DIXON 110540092 24.46 418.23 102.39 15 1800 MILE 6.07 2.62 1.91 10.60 13.86 1. <= 10%MARIPOSA 2102 MARIPOSA 210210880 39.25 901.89 101.36 16 1800 MILE 28.35 2.12 6.17 36.65 2.60 1. <= 10%SHINGLE SPRINGS 2109 SHINGLE SPRINGS 210913322 40.40 1742.54 99.59 17 1800 MILE 35.50 0.24 0.00 35.74 4.66 1. <= 10%AUBERRY 1101 AUBERRY 1101R2578 42.35 1543.29 99.46 18 1800 MILE 13.63 2.05 12.52 28.20 14.14 1. <= 10%WISE 1102 WISE 11022230 23.89 705.05 97.20 19 1800 MILE 17.59 0.30 0.00 17.89 6.00 1. <= 10%OREGON TRAIL 1104 OREGON TRAIL 1104circuit_breaker 10.72 659.85 95.23 20 1800 MILE 0.67 1.01 0.00 1.68 9.04 1. <= 10%UKIAH 1111 UKIAH 1111534 18.28 1145.63 91.00 21 1800 MILE 7.10 0.18 6.25 13.53 4.75 1. <= 10%CEDAR CREEK 1101 CEDAR CREEK 11011664 28.93 2298.21 90.07 22 1800 MILE 6.94 0.51 4.29 11.74 17.19 1. <= 10%PUEBLO 2103 PUEBLO 2103678 34.57 3953.46 89.85 23 1800 MILE 7.70 1.61 2.55 11.86 22.71 1. <= 10%STILLWATER 1102 STILLWATER 1102circuit_breaker 24.40 1386.84 89.61 24 1800 MILE 12.83 1.96 0.00 14.79 9.61 1. <= 10%DIAMOND SPRINGS 1105 DIAMOND SPRINGS 11052102 35.12 1931.38 88.19 25 1800 MILE 0.82 ‐0.02 0.00 0.80 34.32 1. <= 10%BRIDGEVILLE 1102 BRIDGEVILLE 1102circuit_breaker 25.27 2534.24 84.19 26 1800 MILE 4.85 0.62 4.26 9.73 15.54 1. <= 10%HIGGINS 1109 HIGGINS 1109circuit_breaker 26.34 1247.19 82.50 27 1800 MILE 10.55 1.51 2.84 14.89 11.45 1. <= 10%PIKE CITY 1101 PIKE CITY 1101circuit_breaker 19.42 4458.09 80.99 28 1800 MILE 2.96 0.64 2.54 6.15 13.27 1. <= 10%GARBERVILLE 1102 GARBERVILLE 110256048 4.84 2568.29 79.70 29 1800 MILE 0.04 0.00 0.74 0.78 4.07 1. <= 10%CEDAR CREEK 1101 CEDAR CREEK 11011656 31.31 4190.48 79.01 30 1800 MILE 0.00 0.00 0.00 0.00 31.31 1. <= 10%FITCH MOUNTAIN 1113 FITCH MOUNTAIN 11136751 20.60 3310.72 78.26 31 1800 MILE 1.27 0.00 0.00 1.27 19.33 1. <= 10%RED BLUFF 1101 RED BLUFF 11011334 39.97 674.19 77.91 32 1800 MILE 0.00 3.09 0.00 3.09 36.89 1. <= 10%LAYTONVILLE 1102 LAYTONVILLE 1102500 14.71 1702.73 74.61 33 1800 MILE 0.62 0.98 0.77 2.36 12.35 1. <= 10%OAKHURST 1103 OAKHURST 1103circuit_breaker 30.21 1548.50 74.36 34 1800 MILE 3.95 1.46 2.72 8.13 22.08 1. <= 10%MOUNTAIN QUARRIES 2101 MOUNTAIN QUARRIES 2101circuit_breaker 25.84 918.86 72.73 35 1800 MILE 23.15 0.16 0.00 23.32 2.52 1. <= 10%VACAVILLE 1108 VACAVILLE 110838316 16.58 403.82 72.26 36 1800 MILE 12.51 0.41 4.19 16.58 0.00 1. <= 10%CEDAR CREEK 1101 CEDAR CREEK 11011608 32.90 2930.85 71.51 37 1800 MILE 3.09 0.64 0.00 3.73 29.17 1. <= 10%BELL 1107 BELL 11072400 10.05 800.42 69.05 38 1800 MILE 7.14 0.05 0.00 7.19 2.86 1. <= 10%PHILO 1101 PHILO 110137222 24.50 1347.35 68.46 39 1800 MILE 0.00 0.00 0.00 0.00 24.50 1. <= 10%SAN JOAQUIN NO2 1103 SAN JOAQUIN #2 1103circuit_breaker 67.31 1543.75 67.24 40 1800 MILE 0.00 0.00 0.00 0.00 67.31 1. <= 10%SALMON CREEK 1101 SALMON CREEK 110188998 7.63 523.07 66.34 41 1800 MILE 4.83 0.28 1.06 6.16 1.47 1. <= 10%FRUITLAND 1142 FRUITLAND 114293234 10.69 1938.31 66.00 42 1800 MILE 0.00 0.00 0.00 0.00 10.69 1. <= 10%DESCHUTES 1104 DESCHUTES 110449024 16.03 274.04 65.93 43 1800 MILE 11.19 0.74 0.00 11.93 4.10 1. <= 10%AUBERRY 1102 AUBERRY 1102circuit_breaker 33.25 517.33 65.71 44 1800 MILE 1.50 0.00 19.24 20.74 12.51 1. <= 10%STILLWATER 1102 STILLWATER 110248952 10.65 501.33 64.19 45 1800 MILE 5.07 0.35 0.00 5.42 5.24 1. <= 10%OAKHURST 1103 OAKHURST 110363334 15.27 534.46 63.94 46 1800 MILE 4.45 0.94 3.20 8.60 6.67 1. <= 10%BELL 1108 BELL 11082202 29.43 891.93 63.87 47 1800 MILE 14.99 3.40 12.67 29.43 0.00 1. <= 10%WYANDOTTE 1109 WYANDOTTE 110979932 21.15 630.61 63.48 48 1800 MILE 8.05 2.08 0.00 10.13 11.01 1. <= 10%WILLITS 1103 WILLITS 110391810 27.13 3745.77 62.65 49 1800 MILE 5.12 0.05 2.43 7.59 19.55 1. <= 10%GEYSERVILLE 1101 GEYSERVILLE 1101166 11.13 1016.10 62.20 50 1800 MILE 2.41 0.76 2.07 5.13 5.99 1. <= 10%WOODSIDE 1101 WOODSIDE 11018974 11.55 4187.53 62.16 51 1800 MILE 1.36 0.11 0.76 2.24 9.31 1. <= 10%SILVERADO 2104 SILVERADO 2104632 7.59 742.09 61.81 52 1800 MILE 1.66 0.06 0.63 2.34 5.25 1. <= 10%MARIPOSA 2102 MARIPOSA 210237282 52.14 1212.93 60.81 53 1800 MILE 9.95 1.17 5.79 16.92 35.22 1. <= 10%DESCHUTES 1104 DESCHUTES 11049718 20.59 421.88 60.54 54 1800 MILE 0.34 0.00 0.00 0.34 20.25 1. <= 10%OAKHURST 1101 OAKHURST 11015490 10.50 497.19 59.47 55 1800 MILE 7.80 0.09 1.59 9.63 0.87 1. <= 10%COTTONWOOD 1101 COTTONWOOD 110168190 23.87 602.76 58.36 56 1800 MILE 0.00 0.00 0.00 0.00 23.87 1. <= 10%PHILO 1101 PHILO 1101circuit_breaker 32.49 2622.59 57.81 57 1800 MILE 0.00 0.00 0.00 0.00 32.49 1. <= 10%STILLWATER 1102 STILLWATER 11021644 22.77 905.98 56.90 58 1800 MILE 11.89 3.43 0.00 15.32 7.45 1. <= 10%COARSEGOLD 2103 COARSEGOLD 210310820 27.60 467.82 56.49 59 1800 MILE 12.39 5.69 6.52 24.61 2.99 1. <= 10%APPLE HILL 2102 APPLE HILL 21021532 37.07 3569.71 56.04 60 1800 MILE 0.00 0.03 0.00 0.03 37.05 1. <= 10%GIRVAN 1101 GIRVAN 1101323094 35.31 1389.31 55.66 61 1800 MILE 0.00 0.00 0.00 0.00 35.31 1. <= 10%LAYTONVILLE 1102 LAYTONVILLE 1102572 20.62 2694.95 55.53 62 1800 MILE 0.00 0.00 0.00 0.00 20.62 1. <= 10%PIKE CITY 1102 PIKE CITY 1102circuit_breaker 9.42 2708.54 55.33 63 1800 MILE 0.11 0.37 1.52 2.00 7.42 1. <= 10%BROWNS VALLEY 1101 BROWNS VALLEY 110193870 20.83 564.97 55.08 64 1800 MILE 12.13 2.55 4.25 18.93 1.90 1. <= 10%ANTLER 1101 ANTLER 11011378 24.27 2949.37 54.01 65 1800 MILE 0.00 0.00 0.00 0.00 24.27 1. <= 10%CHALLENGE 1102 CHALLENGE 1102circuit_breaker 14.67 3651.32 53.45 66 1800 MILE 0.23 0.10 1.64 1.97 12.70 1. <= 10%LAYTONVILLE 1102 LAYTONVILLE 110237586 13.88 1272.33 52.81 67 1800 MILE 0.09 0.00 0.00 0.09 13.79 1. <= 10%HOOPA 1101 HOOPA 11013290 12.86 1552.94 52.56 68 1800 MILE 0.30 0.25 0.00 0.56 12.30 1. <= 10%PENRYN 1105 PENRYN 11051342 22.49 877.49 52.37 69 1800 MILE 0.42 2.32 3.35 6.08 16.41 1. <= 10%KANAKA 1101 KANAKA 110165606 12.84 3194.72 51.40 70 1800 MILE 0.08 0.18 1.38 1.64 11.21 1. <= 10%LINCOLN 1104 LINCOLN 11042070 20.61 602.85 50.50 71 1800 MILE 11.64 1.43 1.72 14.79 5.82 1. <= 10%WYANDOTTE 1103 WYANDOTTE 11031974 23.01 4221.08 49.63 72 1800 MILE 0.17 0.00 0.00 0.18 22.83 1. <= 10%COTTONWOOD 1102 COTTONWOOD 11021578 29.49 1137.09 49.54 73 1800 MILE 0.00 0.00 0.00 0.00 29.49 1. <= 10%PENRYN 1103 PENRYN 11032198 16.81 594.74 48.91 74 1800 MILE 4.56 1.56 0.00 6.12 10.69 1. <= 10%LAS GALLINAS A 1105 LAS GALLINAS A 110599904 5.44 739.24 48.84 75 1800 MILE 0.20 0.45 0.77 1.42 4.01 1. <= 10%PLACERVILLE 2106 PLACERVILLE 21067522 65.19 6799.49 48.76 76 1800 MILE 0.09 1.66 8.50 10.25 54.94 1. <= 10%DESCHUTES 1104 DESCHUTES 11049726 14.64 255.19 48.68 77 2400 MILE 11.27 0.26 0.00 11.53 3.11 1. <= 10%GRASS VALLEY 1103 GRASS VALLEY 11032180 44.19 2408.35 48.35 78 2400 MILE 3.94 2.78 6.87 13.59 30.60 1. <= 10%HIGGINS 1109 HIGGINS 110950078 46.97 844.79 47.47 79 2400 MILE 12.58 5.96 6.30 24.84 22.12 1. <= 10%HOOPA 1101 HOOPA 11013174 17.96 2544.24 47.27 80 2400 MILE 0.00 0.33 0.00 0.33 17.63 1. <= 10%SHINGLE SPRINGS 2109 SHINGLE SPRINGS 21099372 18.60 589.09 47.13 81 2400 MILE 0.84 0.00 0.00 0.84 17.76 1. <= 10%COTTONWOOD 1101 COTTONWOOD 11011610 36.98 1026.81 47.08 82 2400 MILE 0.00 0.00 0.00 0.00 36.98 1. <= 10%DESCHUTES 1104 DESCHUTES 1104circuit_breaker 12.88 274.71 47.06 83 2400 MILE 9.84 0.38 0.00 10.23 2.66 1. <= 10%NARROWS 2101 NARROWS 21011202 45.52 1236.96 46.92 84 2400 MILE 0.00 0.00 0.00 0.00 45.52 1. <= 10%GARBERVILLE 1102 GARBERVILLE 11024744 17.05 1491.09 46.69 85 2400 MILE 0.00 0.00 0.00 0.00 17.05 1. <= 10%ZACA 1102 ZACA 1102Y54 31.63 421.35 46.13 86 2400 MILE 0.00 0.00 0.00 0.00 31.63 1. <= 10%CALISTOGA 1101 CALISTOGA 1101734 6.58 851.52 45.87 87 2400 MILE 0.01 0.00 0.00 0.01 6.57 1. <= 10%DESCHUTES 1101 DESCHUTES 11011380 17.28 492.84 45.46 88 2400 MILE 0.00 0.00 0.00 0.00 17.28 1. <= 10%MARIPOSA 2102 MARIPOSA 21029590 35.79 1638.67 45.03 89 2400 MILE 0.00 0.00 0.00 0.00 35.79 1. <= 10%FRUITLAND 1142 FRUITLAND 114263170 11.76 2045.73 44.77 90 2400 MILE 0.00 0.00 0.00 0.00 11.76 1. <= 10%WISE 1102 WISE 11022054 13.39 354.51 44.54 91 2400 MILE 0.32 0.00 0.00 0.32 13.07 1. <= 10%SHINGLE SPRINGS 2110 SHINGLE SPRINGS 21107742 45.20 2517.81 43.79 92 2400 MILE 0.00 0.00 0.00 0.00 45.20 1. <= 10%SAND CREEK 1103 SAND CREEK 110345190 36.37 653.37 43.65 93 2400 MILE 0.00 0.00 0.00 0.00 36.37 1. <= 10%DIAMOND SPRINGS 1105 DIAMOND SPRINGS 110519910 19.31 547.20 43.15 94 2400 MILE 0.48 0.00 0.00 0.48 18.83 1. <= 10%ELK CREEK 1101 ELK CREEK 11012106 13.25 418.97 42.98 95 2400 MILE 0.00 0.00 0.00 0.00 13.25 1. <= 10%DOBBINS 1101 DOBBINS 11011264 35.61 3459.03 42.85 96 2400 MILE 0.00 0.00 0.00 0.00 35.61 1. <= 10%GIRVAN 1101 GIRVAN 11011330 30.57 1827.81 42.57 97 1800 MILE 0.00 0.00 0.00 0.00 30.57 1. <= 10%VOLTA 1101 VOLTA 110180454 32.11 2042.39 42.57 98 2400 MILE 0.00 0.00 0.00 0.00 32.11 1. <= 10%TIVY VALLEY 1107 TIVY VALLEY 1107R1817 14.59 813.34 42.38 99 2400 MILE 9.16 1.31 0.00 10.59 4.00 1. <= 10%AUBERRY 1102 AUBERRY 1102R2850 26.34 405.00 42.15 100 2400 MILE 0.00 0.00 0.00 0.00 26.34 1. <= 10%BELL 1107 BELL 110750172 5.45 377.12 41.29 103 2400 MILE 3.77 0.00 0.00 3.77 1.68 1. <= 10%SILVERADO 2104 SILVERADO 210478268 6.20 692.14 18.92 243 2400 MILE 1.11 0.00 0.00 1.11 5.09 1. <= 10%SAN LUIS OBISPO 1107 SAN LUIS OBISPO 1107V60 15.52 654.60 4.49 650 2400 MILE 3.84 0.00 0.00 3.84 11.68 3. >20 ‐ 30%WISHON 1101 WISHON 1101circuit_breaker 5.31 317.00 2.47 827 2400 MILE 0.00 0.00 0.00 0.00 5.31 3. >20 ‐ 30%

Total 2522.19 173408.40 7215.03 512.39 90.87 200.62 802.26 1719.93


AtchL-2 APP3-77





Miles Complete and Verified (Actual) as of 6/30/21 (Audited)

Miles Complete and Verified

(Actual) 07/01/21 ‐ 07/18/21 (Unaudited)


(Unaudited)


(Unaudited)

Miles Complete and Verified (Actual +

Forecasted) as of 11/01/21

(Unaudited)

Remaining Miles

(Unaudited)


RIO DELL 1102 RIO DELL 11024230 22.82 4236.60 202.04 1 1800 MILE 1.71 0.23 1.89 10.81 14.63 8.19 1. <= 10%APPLE HILL 2102 APPLE HILL 2102circuit_breaker 38.41 4581.57 175.16 2 1800 MILE 4.04 4.66 5.21 18.02 31.93 6.48 1. <= 10%FORT SEWARD 1121 FORT SEWARD 11211690 10.43 1715.01 153.25 3 1800 MILE 3.30 0.39 1.53 1.11 6.33 4.10 1. <= 10%OAKHURST 1101 OAKHURST 110110090 31.38 1754.73 134.58 4 1800 MILE 11.48 0.23 2.66 1.93 16.57 14.81 1. <= 10%OREGON TRAIL 1104 OREGON TRAIL 11041574 15.86 629.46 133.27 5 1800 MILE 4.09 2.19 3.88 1.41 11.56 4.30 1. <= 10%MIDDLETOWN 1101 MIDDLETOWN 1101622 12.05 939.18 129.25 6 1800 MILE 4.28 0.82 1.11 0.91 7.23 4.82 1. <= 10%BIG BEND 1102 BIG BEND 11021972 21.06 4537.67 122.68 7 1800 MILE 0.23 0.17 0.00 21.06 21.06 0.00 1. <= 10%DESCHUTES 1104 DESCHUTES 11041370 14.73 481.79 119.37 8 1800 MILE 9.90 0.58 0.00 0.00 10.48 4.24 1. <= 10%DESCHUTES 1101 DESCHUTES 11011580 45.36 2608.48 115.48 9 1800 MILE 18.74 4.92 6.52 37.33 45.36 0.00 1. <= 10%HIGGINS 1109 HIGGINS 110950072 50.94 2058.04 109.83 10 1800 MILE 3.91 0.99 5.90 33.78 44.58 6.36 1. <= 10%DIAMOND SPRINGS 1105 DIAMOND SPRINGS 11057722 47.85 2812.35 108.10 11 1800 MILE 28.23 7.08 8.14 28.12 47.85 0.00 1. <= 10%OREGON TRAIL 1104 OREGON TRAIL 11041634 17.00 444.45 105.89 12 1800 MILE 5.09 4.03 2.49 14.10 17.00 0.00 1. <= 10%CHALLENGE 1102 CHALLENGE 11021064 20.30 3727.17 105.13 13 1800 MILE 1.76 0.05 1.52 8.73 12.06 8.24 1. <= 10%BANGOR 1101 BANGOR 11017446 28.47 4060.54 103.42 14 1800 MILE 18.15 1.31 4.03 0.00 23.48 4.98 1. <= 10%VACA DIXON 1105 VACA DIXON 110540092 24.46 418.23 102.39 15 1800 MILE 6.07 2.62 0.95 20.02 24.46 0.00 1. <= 10%MARIPOSA 2102 MARIPOSA 210210880 39.25 901.89 101.36 16 1800 MILE 28.35 2.12 4.85 3.53 38.85 0.39 1. <= 10%SHINGLE SPRINGS 2109 SHINGLE SPRINGS 210913322 40.40 1742.54 99.59 17 1800 MILE 35.50 0.24 0.00 0.00 35.74 4.66 1. <= 10%AUBERRY 1101 AUBERRY 1101R2578 42.35 1543.29 99.46 18 1800 MILE 13.63 2.05 9.84 7.16 32.68 9.67 1. <= 10%WISE 1102 WISE 11022230 23.89 705.05 97.20 19 1800 MILE 17.59 0.30 0.00 0.00 17.89 6.00 1. <= 10%OREGON TRAIL 1104 OREGON TRAIL 1104circuit_breaker 10.72 659.85 95.23 20 1800 MILE 0.67 1.01 0.00 10.72 10.72 0.00 1. <= 10%UKIAH 1111 UKIAH 1111534 18.28 1145.63 91.00 21 1800 MILE 7.10 0.18 4.58 1.25 13.11 5.17 1. <= 10%CEDAR CREEK 1101 CEDAR CREEK 11011664 28.93 2298.21 90.07 22 1800 MILE 6.94 0.51 3.37 19.31 28.93 0.00 1. <= 10%PUEBLO 2103 PUEBLO 2103678 34.57 3953.46 89.85 23 1800 MILE 7.70 1.61 2.01 11.49 22.80 11.77 1. <= 10%STILLWATER 1102 STILLWATER 1102circuit_breaker 24.40 1386.84 89.61 24 1800 MILE 12.83 1.96 0.00 0.00 14.79 9.61 1. <= 10%DIAMOND SPRINGS 1105 DIAMOND SPRINGS 11052102 35.12 1931.38 88.19 25 1800 MILE 0.82 ‐0.02 0.00 20.97 21.77 13.35 1. <= 10%BRIDGEVILLE 1102 BRIDGEVILLE 1102circuit_breaker 25.27 2534.24 84.19 26 1800 MILE 4.85 0.62 3.35 12.47 21.29 3.98 1. <= 10%HIGGINS 1109 HIGGINS 1109circuit_breaker 26.34 1247.19 82.50 27 1800 MILE 10.55 1.51 2.23 5.67 19.96 6.38 1. <= 10%PIKE CITY 1101 PIKE CITY 1101circuit_breaker 19.42 4458.09 80.99 28 1800 MILE 2.96 0.64 2.00 9.44 15.04 4.38 1. <= 10%GARBERVILLE 1102 GARBERVILLE 110256048 4.84 2568.29 79.70 29 1800 MILE 0.04 0.00 0.42 4.32 4.78 0.07 1. <= 10%CEDAR CREEK 1101 CEDAR CREEK 11011656 31.31 4190.48 79.01 30 1800 MILE 0.00 0.00 0.00 13.88 13.88 17.42 1. <= 10%FITCH MOUNTAIN 1113 FITCH MOUNTAIN 11136751 20.60 3310.72 78.26 31 1800 MILE 1.27 0.00 0.00 20.60 20.60 0.00 1. <= 10%RED BLUFF 1101 RED BLUFF 11011334 39.97 674.19 77.91 32 1800 MILE 0.00 3.09 0.00 16.56 19.65 20.32 1. <= 10%LAYTONVILLE 1102 LAYTONVILLE 1102500 14.71 1702.73 74.61 33 1800 MILE 0.62 0.98 0.00 20.45 14.71 0.00 1. <= 10%OAKHURST 1103 OAKHURST 1103circuit_breaker 30.21 1548.50 74.36 34 1800 MILE 3.95 1.46 2.14 12.25 19.79 10.42 1. <= 10%MOUNTAIN QUARRIES 2101 MOUNTAIN QUARRIES 2101circuit_breaker 25.84 918.86 72.73 35 1800 MILE 23.15 0.16 0.00 0.00 23.32 2.52 1. <= 10%VACAVILLE 1108 VACAVILLE 110838316 16.58 403.82 72.26 36 1800 MILE 12.51 0.41 3.30 1.50 16.58 0.00 1. <= 10%CEDAR CREEK 1101 CEDAR CREEK 11011608 32.90 2930.85 71.51 37 1800 MILE 3.09 0.64 0.00 12.85 16.58 16.32 1. <= 10%BELL 1107 BELL 11072400 10.05 800.42 69.05 38 1800 MILE 7.14 0.05 0.00 0.00 7.19 2.86 1. <= 10%PHILO 1101 PHILO 110137222 24.50 1347.35 68.46 39 1800 MILE 0.00 0.00 0.00 24.71 24.50 0.00 1. <= 10%SAN JOAQUIN NO2 1103 SAN JOAQUIN #2 1103circuit_breaker 67.31 1543.75 67.24 40 1800 MILE 0.00 0.00 0.00 0.00 0.00 67.31 1. <= 10%SALMON CREEK 1101 SALMON CREEK 110188998 7.63 523.07 66.34 41 1800 MILE 4.83 0.28 0.83 0.68 6.61 1.02 1. <= 10%FRUITLAND 1142 FRUITLAND 114293234 10.69 1938.31 66.00 42 1800 MILE 0.00 0.00 0.00 7.22 7.22 3.47 1. <= 10%DESCHUTES 1104 DESCHUTES 110449024 16.03 274.04 65.93 43 1800 MILE 11.19 0.74 0.00 0.00 11.93 4.10 1. <= 10%AUBERRY 1102 AUBERRY 1102circuit_breaker 33.25 517.33 65.71 44 1800 MILE 1.50 0.00 12.03 19.24 32.76 0.49 1. <= 10%STILLWATER 1102 STILLWATER 110248952 10.65 501.33 64.19 45 1800 MILE 5.07 0.35 0.00 0.00 5.42 5.24 1. <= 10%OAKHURST 1103 OAKHURST 110363334 15.27 534.46 63.94 46 1800 MILE 4.45 0.94 2.52 7.10 15.01 0.26 1. <= 10%BELL 1108 BELL 11082202 29.43 891.93 63.87 47 1800 MILE 14.99 3.40 9.96 7.24 29.43 0.00 1. <= 10%WYANDOTTE 1109 WYANDOTTE 110979932 21.15 630.61 63.48 48 1800 MILE 8.05 2.08 0.00 0.00 10.13 11.01 1. <= 10%WILLITS 1103 WILLITS 110391810 27.13 3745.77 62.65 49 1800 MILE 5.12 0.05 1.91 10.91 17.98 9.15 1. <= 10%GEYSERVILLE 1101 GEYSERVILLE 1101166 11.13 1016.10 62.20 50 1800 MILE 2.41 0.76 1.63 1.33 6.02 5.11 1. <= 10%WOODSIDE 1101 WOODSIDE 11018974 11.55 4187.53 62.16 51 1800 MILE 1.36 0.11 0.60 3.44 5.51 6.04 1. <= 10%SILVERADO 2104 SILVERADO 2104632 7.59 742.09 61.81 52 1800 MILE 1.66 0.06 0.50 2.84 5.05 2.54 1. <= 10%MARIPOSA 2102 MARIPOSA 210237282 52.14 1212.93 60.81 53 1800 MILE 9.95 1.17 4.55 26.07 41.74 10.39 1. <= 10%DESCHUTES 1104 DESCHUTES 11049718 20.59 421.88 60.54 54 1800 MILE 0.34 0.00 0.00 0.00 0.34 20.25 1. <= 10%OAKHURST 1101 OAKHURST 11015490 10.50 497.19 59.47 55 1800 MILE 7.80 0.09 1.25 2.05 10.50 0.00 1. <= 10%COTTONWOOD 1101 COTTONWOOD 110168190 23.87 602.76 58.36 56 1800 MILE 0.00 0.00 0.00 0.71 0.71 23.15 1. <= 10%PHILO 1101 PHILO 1101circuit_breaker 32.49 2622.59 57.81 57 1800 MILE 0.00 0.00 0.00 1.42 1.42 31.06 1. <= 10%STILLWATER 1102 STILLWATER 11021644 22.77 905.98 56.90 58 1800 MILE 11.89 3.43 0.00 0.70 16.02 6.75 1. <= 10%COARSEGOLD 2103 COARSEGOLD 210310820 27.60 467.82 56.49 59 1800 MILE 12.39 5.69 5.13 8.39 27.60 0.00 1. <= 10%APPLE HILL 2102 APPLE HILL 21021532 37.07 3569.71 56.04 60 1800 MILE 0.00 0.03 0.00 19.88 19.90 17.17 1. <= 10%GIRVAN 1101 GIRVAN 1101323094 35.31 1389.31 55.66 61 1800 MILE 0.00 0.00 0.00 1.08 1.08 34.22 1. <= 10%LAYTONVILLE 1102 LAYTONVILLE 1102572 20.62 2694.95 55.53 62 1800 MILE 0.00 0.00 0.00 0.00 0.00 20.62 1. <= 10%PIKE CITY 1102 PIKE CITY 1102circuit_breaker 9.42 2708.54 55.33 63 1800 MILE 0.11 0.37 1.19 6.82 8.49 0.92 1. <= 10%BROWNS VALLEY 1101 BROWNS VALLEY 110193870 20.83 564.97 55.08 64 1800 MILE 12.13 2.55 4.25 0.00 18.93 1.90 1. <= 10%ANTLER 1101 ANTLER 11011378 24.27 2949.37 54.01 65 1800 MILE 0.00 0.00 0.00 0.75 0.75 23.52 1. <= 10%CHALLENGE 1102 CHALLENGE 1102circuit_breaker 14.67 3651.32 53.45 66 1800 MILE 0.23 0.10 1.29 7.39 9.00 5.67 1. <= 10%LAYTONVILLE 1102 LAYTONVILLE 110237586 13.88 1272.33 52.81 67 1800 MILE 0.09 0.00 0.00 0.00 0.09 13.79 1. <= 10%HOOPA 1101 HOOPA 11013290 12.86 1552.94 52.56 68 1800 MILE 0.30 0.25 0.00 8.54 9.09 3.76 1. <= 10%PENRYN 1105 PENRYN 11051342 22.49 877.49 52.37 69 1800 MILE 0.42 2.32 0.84 19.26 22.49 0.00 1. <= 10%KANAKA 1101 KANAKA 110165606 12.84 3194.72 51.40 70 1800 MILE 0.08 0.18 1.08 6.21 7.55 5.29 1. <= 10%LINCOLN 1104 LINCOLN 11042070 20.61 602.85 50.50 71 1800 MILE 11.64 1.43 1.72 0.00 14.79 5.82 1. <= 10%WYANDOTTE 1103 WYANDOTTE 11031974 23.01 4221.08 49.63 72 1800 MILE 0.17 0.00 0.00 20.36 20.53 2.47 1. <= 10%COTTONWOOD 1102 COTTONWOOD 11021578 29.49 1137.09 49.54 73 1800 MILE 0.00 0.00 0.00 0.85 0.85 28.64 1. <= 10%PENRYN 1103 PENRYN 11032198 16.81 594.74 48.91 74 1800 MILE 4.56 1.56 0.00 0.00 6.12 10.69 1. <= 10%LAS GALLINAS A 1105 LAS GALLINAS A 110599904 5.44 739.24 48.84 75 1800 MILE 0.20 0.45 0.61 3.48 4.74 0.69 1. <= 10%PLACERVILLE 2106 PLACERVILLE 21067522 65.19 6799.49 48.76 76 1800 MILE 0.09 1.66 6.68 38.26 46.69 18.50 1. <= 10%DESCHUTES 1104 DESCHUTES 11049726 14.64 255.19 48.68 77 2400 MILE 11.27 0.26 0.00 0.00 11.53 3.11 1. <= 10%GRASS VALLEY 1103 GRASS VALLEY 11032180 44.19 2408.35 48.35 78 2400 MILE 3.94 2.78 5.40 30.93 43.05 1.14 1. <= 10%HIGGINS 1109 HIGGINS 110950078 46.97 844.79 47.47 79 2400 MILE 12.58 5.96 4.58 36.08 46.97 0.00 1. <= 10%HOOPA 1101 HOOPA 11013174 17.96 2544.24 47.27 80 2400 MILE 0.00 0.33 0.00 3.60 3.93 14.03 1. <= 10%SHINGLE SPRINGS 2109 SHINGLE SPRINGS 21099372 18.60 589.09 47.13 81 2400 MILE 0.84 0.00 0.00 11.37 12.21 6.40 1. <= 10%COTTONWOOD 1101 COTTONWOOD 11011610 36.98 1026.81 47.08 82 2400 MILE 0.00 0.00 0.00 1.76 1.76 35.22 1. <= 10%DESCHUTES 1104 DESCHUTES 1104circuit_breaker 12.88 274.71 47.06 83 2400 MILE 9.84 0.38 0.00 0.00 10.23 2.66 1. <= 10%NARROWS 2101 NARROWS 21011202 45.52 1236.96 46.92 84 2400 MILE 0.00 0.00 0.00 15.90 15.90 29.62 1. <= 10%GARBERVILLE 1102 GARBERVILLE 11024744 17.05 1491.09 46.69 85 2400 MILE 0.00 0.00 0.00 7.41 7.41 9.65 1. <= 10%ZACA 1102 ZACA 1102Y54 31.63 421.35 46.13 86 2400 MILE 0.00 0.00 0.00 27.73 27.73 3.90 1. <= 10%CALISTOGA 1101 CALISTOGA 1101734 6.58 851.52 45.87 87 2400 MILE 0.01 0.00 0.00 2.22 2.23 4.36 1. <= 10%DESCHUTES 1101 DESCHUTES 11011380 17.28 492.84 45.46 88 2400 MILE 0.00 0.00 0.00 0.75 0.75 16.53 1. <= 10%MARIPOSA 2102 MARIPOSA 21029590 35.79 1638.67 45.03 89 2400 MILE 0.00 0.00 0.00 18.75 18.75 17.05 1. <= 10%FRUITLAND 1142 FRUITLAND 114263170 11.76 2045.73 44.77 90 2400 MILE 0.00 0.00 0.00 4.02 4.02 7.74 1. <= 10%WISE 1102 WISE 11022054 13.39 354.51 44.54 91 2400 MILE 0.32 0.00 0.00 8.23 8.55 4.84 1. <= 10%SHINGLE SPRINGS 2110 SHINGLE SPRINGS 21107742 45.20 2517.81 43.79 92 2400 MILE 0.00 0.00 0.00 28.55 28.55 16.65 1. <= 10%SAND CREEK 1103 SAND CREEK 110345190 36.37 653.37 43.65 93 2400 MILE 0.00 0.00 0.00 9.13 9.13 27.24 1. <= 10%DIAMOND SPRINGS 1105 DIAMOND SPRINGS 110519910 19.31 547.20 43.15 94 2400 MILE 0.48 0.00 0.00 20.87 19.31 0.00 1. <= 10%ELK CREEK 1101 ELK CREEK 11012106 13.25 418.97 42.98 95 2400 MILE 0.00 0.00 0.00 0.61 0.61 12.65 1. <= 10%DOBBINS 1101 DOBBINS 11011264 35.61 3459.03 42.85 96 2400 MILE 0.00 0.00 0.00 12.44 12.44 23.17 1. <= 10%GIRVAN 1101 GIRVAN 11011330 30.57 1827.81 42.57 97 1800 MILE 0.00 0.00 0.00 1.37 1.37 29.20 1. <= 10%VOLTA 1101 VOLTA 110180454 32.11 2042.39 42.57 98 2400 MILE 0.00 0.00 0.00 1.45 1.45 30.66 1. <= 10%TIVY VALLEY 1107 TIVY VALLEY 1107R1817 14.59 813.34 42.38 99 2400 MILE 9.16 1.31 0.00 3.44 14.03 0.55 1. <= 10%AUBERRY 1102 AUBERRY 1102R2850 26.34 405.00 42.15 100 2400 MILE 0.00 0.00 0.00 6.60 6.60 19.73 1. <= 10%BELL 1107 BELL 110750172 5.45 377.12 41.29 103 2400 MILE 3.77 0.00 0.00 0.00 3.77 1.68 1. <= 10%SILVERADO 2104 SILVERADO 210478268 6.20 692.14 18.92 243 2400 MILE 1.11 0.00 0.00 0.00 1.11 5.09 1. <= 10%SAN LUIS OBISPO 1107 SAN LUIS OBISPO 1107V60 15.52 654.60 4.49 650 2400 MILE 3.84 0.00 0.00 0.00 3.84 11.68 3. >20 ‐ 30%WISHON 1101 WISHON 1101circuit_breaker 5.31 317.00 2.47 827 2400 MILE 0.00 0.00 0.00 0.00 0.00 5.31 3. >20 ‐ 30%

Total 2522.19 173408.40 7215.03 512.39 90.87 152.44 911.86 1569.49 952.70

Note: “As part of EVM’s process, a circuit segment categorized as completed (work verified), may revert to an in‐progress status if a new vegetation point (tree) is associated with a circuit segment after the work verification was completed. If this were to occur, miles associated with thiscircuit segment will not be recognized as complete until work verification has been re‐performed. This condition could cause progress which was recognized in one quarter to not be recognized in a subsequent quarter.”

AtchL-3 APP3-78


ATTACHMENT M

RESOURCES AND PERSONNEL FOR NEXT 90 DAYS

(UNAUDITED)

(PUBLIC)

APP3-79

Region Regional Managers

Supervising Vegetation Program Manager (SVPM)

Vegetation Program Manager (VPM)

Bay Area 1 3 3Central Coast 1 1 1Central Valley 1 2 3North Coast 1 2 3North Valley 1 2 2Sierra 1 2 3

6 12 15

Total numbers of employees may change on any given day pending where resources are needed (ie. Another EVM Project, other VM Program, or unprecendented events such as wildfire emergency work and/or

restoration, etc.) PG&E Internal Employees - Assigned to EVM Program

AtchM-1 APP3-80

AtchM-2 APP3-81

AtchM-3 APP3-82


ATTACHMENT N

2021 EVM WORK PERFORMED OUTSIDE THE 2021 EVM

SCOPE OF WORK

APP3-83

Circuit Name Circuit Protection ZoneTree Weighted Risk

ScoreTree Weighted Rank

Plan (Mile Cutoff)

Miles Complete and Verified as of 6/30/21(Audited)

Miles Ready for Work Verification as of 6/30/21

(Unaudited)

Risk Miles by Percentage (Top

20%)SAN JOAQUIN NO2 1103 SAN JOAQUIN #2 110310320 40.84 104 n/a 3.17 2.54 1. <= 10%KONOCTI 1102 KONOCTI 1102circuit_breaker 40.10 108 n/a 0.04 0.00 1. <= 10%WILLITS 1103 WILLITS 1103826 39.92 110 n/a 0.12 0.03 1. <= 10%WILLITS 1102 WILLITS 1102circuit_breaker 39.36 114 n/a 1.26 0.00 1. <= 10%WOODSIDE 1101 WOODSIDE 11018884 38.87 119 n/a 0.00 0.00 1. <= 10%WISE 1102 WISE 1102307494 38.74 121 n/a 0.51 0.02 1. <= 10%CALISTOGA 1101 CALISTOGA 1101736 38.05 125 n/a 0.42 0.04 1. <= 10%SHINGLE SPRINGS 2109 SHINGLE SPRINGS 210912392 37.83 127 n/a 8.26 0.46 1. <= 10%WYANDOTTE 1109 WYANDOTTE 110913052 34.00 137 n/a 2.03 0.08 1. <= 10%DESCHUTES 1104 DESCHUTES 11041582 32.37 145 n/a 0.09 0.04 1. <= 10%WISE 1102 WISE 1102697216 27.78 172 n/a 0.16 0.18 1. <= 10%BROWNS VALLEY 1101 BROWNS VALLEY 11011268 27.43 175 n/a 2.67 0.00 1. <= 10%TIVY VALLEY 1107 TIVY VALLEY 1107584840 26.72 180 n/a 11.96 1.63 1. <= 10%CALISTOGA 1101 CALISTOGA 110189150 26.24 184 n/a 0.05 0.00 1. <= 10%CEDAR CREEK 1101 CEDAR CREEK 1101circuit_breaker 24.23 199 n/a 0.32 0.05 1. <= 10%LINCOLN 1104 LINCOLN 110451756 23.61 202 n/a 9.02 0.07 1. <= 10%MARIPOSA 2101 MARIPOSA 21019400 22.86 211 n/a 0.13 0.00 1. <= 10%MOUNTAIN QUARRIES 2101 MOUNTAIN QUARRIES 21011102 21.93 219 n/a 0.12 0.00 1. <= 10%SHINGLE SPRINGS 2109 SHINGLE SPRINGS 210961892 20.18 232 n/a 0.12 0.00 1. <= 10%AUBERRY 1101 AUBERRY 1101R314 19.03 241 n/a 0.16 0.00 1. <= 10%BELL 1108 BELL 11085703 17.38 261 n/a 0.00 0.04 1. <= 10%GRASS VALLEY 1103 GRASS VALLEY 11032110 17.37 263 n/a 0.67 0.22 1. <= 10%MIDDLETOWN 1101 MIDDLETOWN 1101548 17.25 265 n/a 0.03 0.00 1. <= 10%SILVERADO 2104 SILVERADO 210437632 16.23 281 n/a 0.05 0.00 1. <= 10%KONOCTI 1102 KONOCTI 110275382 15.86 283 n/a 0.08 0.00 1. <= 10%CALISTOGA 1101 CALISTOGA 110143924 15.22 288 n/a 0.00 0.00 1. <= 10%MOUNTAIN QUARRIES 2101 MOUNTAIN QUARRIES 21016953 15.16 289 n/a 0.44 0.00 1. <= 10%KONOCTI 1102 KONOCTI 110264664 14.64 296 n/a 0.12 0.00 1. <= 10%AUBERRY 1101 AUBERRY 1101R2579 13.29 321 n/a 0.60 0.11 1. <= 10%MORGAN HILL 2105 MORGAN HILL 2105XR176 12.32 338 n/a 0.12 0.00 2. >10 ‐ 20%TIVY VALLEY 1107 TIVY VALLEY 1107869946 12.21 341 n/a 10.40 0.36 2. >10 ‐ 20%WYANDOTTE 1109 WYANDOTTE 11091520 11.84 349 n/a 0.00 0.00 2. >10 ‐ 20%SHINGLE SPRINGS 2109 SHINGLE SPRINGS 21092679 11.50 359 n/a 0.29 0.00 2. >10 ‐ 20%WYANDOTTE 1109 WYANDOTTE 11095607 11.37 361 n/a 0.01 0.00 2. >10 ‐ 20%OAKHURST 1103 OAKHURST 110310570 11.13 369 n/a 0.00 0.00 2. >10 ‐ 20%OAKHURST 1103 OAKHURST 11035480 10.70 383 n/a 0.38 0.00 2. >10 ‐ 20%WYANDOTTE 1107 WYANDOTTE 11071026 10.23 400 n/a 0.00 0.00 2. >10 ‐ 20%OREGON TRAIL 1103 OREGON TRAIL 110335002 10.12 402 n/a 0.37 0.00 2. >10 ‐ 20%FORT SEWARD 1121 FORT SEWARD 1121circuit_breaker 9.70 413 n/a 0.29 0.00 2. >10 ‐ 20%BANGOR 1101 BANGOR 11011804 9.09 429 n/a 0.06 0.00 2. >10 ‐ 20%MIDDLETOWN 1101 MIDDLETOWN 1101circuit_breaker 9.09 430 n/a 0.73 0.00 2. >10 ‐ 20%MIDDLETOWN 1101 MIDDLETOWN 110148212 8.95 436 n/a 0.59 0.00 2. >10 ‐ 20%WISE 1102 WISE 11022234 8.77 446 n/a 0.00 0.00 2. >10 ‐ 20%MORGAN HILL 2105 MORGAN HILL 2105XR564 8.40 465 n/a 2.04 0.32 2. >10 ‐ 20%SILVERADO 2104 SILVERADO 2104806 8.31 469 n/a 0.00 0.00 2. >10 ‐ 20%WILLITS 1103 WILLITS 110337504 7.64 496 n/a 0.01 0.00 2. >10 ‐ 20%

AtchN-1 APP3-84



Plan (Mile Cutoff)



(Unaudited)


20%)AUBERRY 1101 AUBERRY 1101R2839 7.47 501 n/a 0.04 0.12 2. >10 ‐ 20%NARROWS 2102 NARROWS 210248484 7.35 503 n/a 1.55 0.55 2. >10 ‐ 20%BANGOR 1101 BANGOR 110131502 7.32 504 n/a 0.05 0.00 2. >10 ‐ 20%MOUNTAIN QUARRIES 2101 MOUNTAIN QUARRIES 21011346 7.19 510 n/a 0.22 0.00 2. >10 ‐ 20%BROWNS VALLEY 1101 BROWNS VALLEY 110117011 7.11 512 n/a 0.15 0.16 2. >10 ‐ 20%WYANDOTTE 1107 WYANDOTTE 110777578 7.09 515 n/a 0.19 0.00 2. >10 ‐ 20%SAN JOAQUIN NO2 1103 SAN JOAQUIN #2 1103157026 6.10 553 n/a 0.13 0.18 2. >10 ‐ 20%UKIAH 1111 UKIAH 111129452 4.79 620 n/a 0.05 0.00 2. >10 ‐ 20%POTTER VALLEY P H 1105 POTTER VALLEY P H 110576498 4.37 658 n/a 0.06 0.00 3. >20 ‐ 30%OLETA 1101 OLETA 11011208 4.12 675 n/a 0.27 0.00 3. >20 ‐ 30%BRUNSWICK 1105 BRUNSWICK 11052210 3.92 692 n/a 0.13 0.00 3. >20 ‐ 30%OREGON TRAIL 1103 OREGON TRAIL 11031500 3.80 703 n/a 1.84 0.00 3. >20 ‐ 30%GEYSERVILLE 1101 GEYSERVILLE 1101circuit_breaker 2.89 780 n/a 0.09 0.16 3. >20 ‐ 30%NARROWS 2102 NARROWS 21022220 2.59 807 n/a 0.03 0.00 3. >20 ‐ 30%BELL 1108 BELL 1108circuit_breaker 2.17 864 n/a 0.02 0.06 3. >20 ‐ 30%OREGON TRAIL 1103 OREGON TRAIL 11031448 2.10 877 n/a 0.31 0.03 3. >20 ‐ 30%OLETA 1101 OLETA 11011217 1.99 896 n/a 0.57 0.00 3. >20 ‐ 30%SHINGLE SPRINGS 2109 SHINGLE SPRINGS 210911092 1.92 910 n/a 0.13 0.00 3. >20 ‐ 30%KONOCTI 1102 KONOCTI 1102948 1.68 960 n/a 0.00 0.00 3. >20 ‐ 30%WYANDOTTE 1107 WYANDOTTE 110796390 1.61 980 n/a 0.09 0.00 4. >30 ‐ 40%KONOCTI 1102 KONOCTI 1102532 1.44 1021 n/a 0.00 0.00 4. >30 ‐ 40%TIVY VALLEY 1107 TIVY VALLEY 11077380 1.42 1025 n/a 3.48 0.06 4. >30 ‐ 40%OLETA 1101 OLETA 11014768 1.41 1028 n/a 0.43 0.00 4. >30 ‐ 40%MORGAN HILL 2105 MORGAN HILL 210542348 1.37 1038 n/a 0.32 0.00 4. >30 ‐ 40%KONOCTI 1102 KONOCTI 1102596 1.20 1095 n/a 0.02 0.00 4. >30 ‐ 40%WOODSIDE 1101 WOODSIDE 11011922 0.84 1198 n/a 0.07 0.02 4. >30 ‐ 40%BRUNSWICK 1106 BRUNSWICK 110663124 0.73 1241 n/a 0.21 0.00 4. >30 ‐ 40%WILLITS 1104 WILLITS 110434008 0.71 1251 n/a 0.08 0.00 4. >30 ‐ 40%SILVERADO 2104 SILVERADO 2104circuit_breaker 0.70 1257 n/a 0.01 0.00 4. >30 ‐ 40%OAKHURST 1101 OAKHURST 1101circuit_breaker 0.66 1268 n/a 0.18 0.05 4. >30 ‐ 40%LINCOLN 1104 LINCOLN 11045391 0.62 1283 n/a 0.37 0.00 4. >30 ‐ 40%OAKHURST 1103 OAKHURST 11035732 0.61 1292 n/a 1.04 0.00 4. >30 ‐ 40%OAKHURST 1103 OAKHURST 11035120 0.56 1317 n/a 0.04 0.07 5. >40 ‐ 50%OLETA 1101 OLETA 110151740 0.48 1386 n/a 0.52 0.00 5. >40 ‐ 50%OAKHURST 1103 OAKHURST 110310190 0.44 1403 n/a 0.02 0.00 5. >40 ‐ 50%KESWICK 1101 KESWICK 11019712 0.43 1418 n/a 0.06 0.00 5. >40 ‐ 50%WILLITS 1102 WILLITS 11021270 0.43 1420 n/a 0.10 0.00 5. >40 ‐ 50%DIAMOND SPRINGS 1105 DIAMOND SPRINGS 1105circuit_breaker 0.42 1424 n/a 0.22 0.00 5. >40 ‐ 50%TIVY VALLEY 1107 TIVY VALLEY 1107circuit_breaker 0.41 1431 n/a 2.26 0.07 5. >40 ‐ 50%RINCON 1103 RINCON 1103568 0.41 1435 n/a 0.68 0.00 5. >40 ‐ 50%BANGOR 1101 BANGOR 11011806 0.35 1478 n/a 0.56 0.00 5. >40 ‐ 50%OAKHURST 1103 OAKHURST 11035470 0.34 1481 n/a 0.02 0.00 5. >40 ‐ 50%MARIPOSA 2101 MARIPOSA 21014410 0.29 1525 n/a 0.05 0.00 5. >40 ‐ 50%OAKHURST 1101 OAKHURST 11016220 0.22 1604 n/a 4.12 0.40 5. >40 ‐ 50%MARIPOSA 2101 MARIPOSA 210135244 0.17 1679 n/a 0.01 0.00 6. >50%PASO ROBLES 1103 PASO ROBLES 1103N58 0.16 1684 n/a 0.07 0.00 6. >50%

AtchN-2 APP3-85



Plan (Mile Cutoff)



(Unaudited)


20%)KONOCTI 1102 KONOCTI 11022293 0.16 1688 n/a 0.05 0.00 6. >50%CURTIS 1705 CURTIS 17058110 0.12 1764 n/a 0.07 0.00 6. >50%RINCON 1103 RINCON 1103circuit_breaker 0.12 1767 n/a 0.02 0.00 6. >50%MORGAN HILL 2105 MORGAN HILL 2105circuit_breaker 0.10 1787 n/a 0.01 0.00 6. >50%BROWNS VALLEY 1101 BROWNS VALLEY 1101circuit_breaker 0.07 1859 n/a 0.04 0.00 6. >50%PUEBLO 2103 PUEBLO 2103694 0.03 2020 n/a 0.15 0.00 6. >50%SOBRANTE 1102 SOBRANTE 1102circuit_breaker 0.01 2149 n/a 3.74 0.00 6. >50%MORGAN HILL 2105 MORGAN HILL 2105XR602 0.00 2260 n/a 0.00 0.00 6. >50%RINCON 1103 RINCON 1103472 0 2775 n/a 0.28 0.00 6. >50%

#N/A Null 0 n/a 0.00 0.00 #N/A

Total 1038.84 83.14 8.13


AtchN-3 APP3-86


ATTACHMENT O

ACTION PLAN IN RESPONSE TO INTERNAL AUDIT REPORT

APP3-87

INTERNAL AUDIT OBSERVATION AND PROPOSED ACTION PLAN

AtchO-1APP3-88

Internal Audit Observation and Request

Objective: Propose an action plan for future representations of risk values from the Wildfire Distribution Risk Model (WDRM)

Background: In the May 21, 2021, Internal Audit report of Enhanced Vegetation Management Tree-Weighted Prioritization List the following ‘data limitation’ was highlighted as an area for future improvement to the WDRM and it’s use.

Issue: During our review, we found some data limitations both in the 2021 Wildfire Distribution Risk Model and in the March 2021 EVM Tree-Weighted List that impacted our ability to fully assess the risk in the resulting March 2021 EVM Scope of Work. These included:

3) While visually reviewing maps, IA noted that high-risk circuit segmentscould extend past a Unified Grid Map boundary into an adjacent Unified GridMap. The risk associated with this portion of a segment may be diluted whencombined with other larger, lower-risk segments within the adjacent UnifiedGrid Map or may be omitted from the analysis if the extension is within a Tier1 area. While this is a known limitation of the current process, EVMshould analyze the overall impact and determine if it needs to beaddressed in future improvements to the analysis.

For item (3), the Utility is reviewing options for modifying its analysis, including segment aggregation processes and will provide an action plan to address this issue by June 28, 2021.

Example: The Low Gap 11012094 CPZ, shown below, could extend from one Unified Grid Map boundary to another.

The risk score calculated from the pixels on the blue-bordered map on the left, could likely be lower…

…than the risk score calculated from the pixels on the green-bordered map on the right. Depending on which set of pixels are aggregated to calculate the risk score the circuit segment rank could differ

AtchO-2APP3-89

Analysis & Proposed Action Plan

Summary of Analysis: PG&E Wildfire Risk acknowledges the limitations of the 2021 approach using additional steps to account for tree density not in WDRM and to consider completed work also not included in the WRDM.

Proposed Solution: The Wildfire Risk team is already addressing the potential risk dilution issue identified by IA by integrating LiDAR data, where available and updated satellite imagery elsewhere, directly into future evolutions of the WDRM (in development in 2021) to avoid post processing in the future.

The future EVM Work Scope will be informed directly by the risk values provided by the WDRM at the pixel level, identify pixels that have completed vegetation work, and provide a prioritization at the Unified Grid Map and CPZ level.

Finally, PG&E has invested in an enterprise data integration and visualization platform to provide asset and vegetation information freely to enterprise and operations users.

Proposed Action Plan:

Step 1: Integration of tree density information from LiDAR data into the next generation WDRM; and performance testing against prior model.

Date: April through July, 2021

Step 2: • Evaluate the impact (degree of shift)

that would be created within the 2021EVM Tree Weighted Prioritization Listusing the new approach

• Present findings and recommendationto Wildfire Risk and VegetationManagement leadership for reviewand approval

Date: September 24, 2021

Step 3: Seek approval for the new approach and prioritization from the Wildfire Risk Governance Steering Committee.

Date: October 29, 2021

AtchO-3APP3-90

CPUC Docket - Online Documents

Documents

Transcript of CPUC Docket - Online Documents