Task: Formula-prediction-context (source dataset: pge-random)

You are given an table region extracted from a real Excel spreadsheet, which is centered around a cell called "Target Cell" (labeled as "[Target Cell]" shown in the table below). The table region below includes up to 10 rows above/below the Target Cell, and 10 columns to the left/right of the Target Cell. 

Your task is to analyze the table context surrounding the Target Cell, and predict the most likely Excel formula that should go in the Target Cell. If multiple formulas are possible, choose the most reasonable or commonly used based on context.

1. Please follow the standard formula syntax in Excel, e.g. always begins with an equal sign (=).
2. Base your predicted formula on the surrounding table context, e.g., column headers, annotations, and data values in nearby cells.
3. No explanation — just output the formula itself in a JSON format: {"formula": "your_formula_here"}.

Input Excel Snippet in Markdown format:
|     |   A | B     |   C | D         | E             | F            | G                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | H                                                        | I          | J          | K          | L   | M   | N                                                            | O                                         |
|----:|----:|:------|----:|:----------|:--------------|:-------------|:-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|:---------------------------------------------------------|:-----------|:-----------|:-----------|:----|:----|:-------------------------------------------------------------|:------------------------------------------|
|  97 |  95 | TURN  | 015 | TURN-015  | 1             | TURN-015.1   | Re PG&E Excel data Attachment 01, Table 2, metric 7 (“Number of utility wildfire ignitions”) and sub-parts: a. Please explain why PG&E has interpreted this item to only include ignitions larger than 10 acres in size. Include any documentation or correspondence supporting PG&E’s interpretation. b. Please explain if and why PG&E interpreted this item differently than SCE and SDG&E, and whether PG&E is in error or the other utilities have erred in their interpretation. c. Please re-produce all rows of #7 (7a-7d) in Excel to include all reportable ignitions in each year for each category. d. Please provide the CPUC reportable ignition database, including all columns and rows, which part (c) is based on. | Katy Morsony; Stephen Green; Eric Borden; Marcel Hawiger | 2021-02-18 | 2021-02-23 | 2021-02-23 | 1.0 |     | Wildfire: Additional detail                                  | Wildfire                                  |
|  98 |  96 | TURN  | 015 | TURN-015  | 2             | TURN-015.2   | Re. PG&E Excel Attachment 01, Table 2, for each of the metrics 3a (fatalities), 5a (structures), and 6a (acreage): Please provide an Excel version of the “PG&E Fire Incident Data 2014-2019” report (i.e. the ignition database as provided to the CPUC) that also includes columns for each of these three metrics for each reportable ignition. Please highlight or otherwise demarcate those “fire incidents” in the database that were included in PG&E’s compilation for its Table 2, but please provide data for all reportable ignitions where available.                                                                                                                                                                    | Katy Morsony; Stephen Green; Eric Borden; Marcel Hawiger | 2021-02-18 | 2021-02-23 | 2021-02-23 | 1.0 |     | Wildfire: Additional detail                                  | Wildfire                                  |
|  99 |  97 | TURN  | 015 | TURN-015  | 3             | TURN-015.3   | Please provide the activity name and total costs forecast for each activity for 2020-2022, annually, that PG&E expects to record to memorandum accounts. Please explain and quantify whether PG&E will record any amounts from activities authorized in its GRC to memorandum accounts.                                                                                                                                                                                                                                                                                                                                                                                                                                              | Katy Morsony; Stephen Green; Eric Borden; Marcel Hawiger | 2021-02-18 | 2021-02-23 | 2021-02-23 | 1.0 |     | Cost forecasts: Additional detail                            | Cost forecasts                            |
| 100 |  98 | TURN  | 015 | TURN-015  | 4             | TURN-015.4   | Re the EVM program, in Excel please provide the number of vegetation-caused ignitions in 2018, 2019, and 2020, respectively, for each of the approximately 2,500 miles “worked” under the program in 2019, separately. If it is not possible to provide vegetation-caused ignitions for each of the approximately 2,500 miles separately please provide vegetation-caused ignitions for each “circuit protection zone” that most closely matches the approximately 2,500 miles of the program accomplished in 2019, separately for each zone. Please provide in Excel and include columns and information with identifying information, including circuit protection zone rank and name from PG&E’s EVM prioritization in 2019.      | Katy Morsony; Stephen Green; Eric Borden; Marcel Hawiger | 2021-02-18 | 2021-02-23 | 2021-02-23 | 1.0 |     | Enhanced Vegetation Management: Proximity to ignitions       | Enhanced Vegetation Management            |
| 101 |  99 | TURN  | 016 | TURN-016  | 1             | TURN-016.1   | RE  PG&E Excel data attachment, Table 12, initiative 7.3.3.17.1 (System hardening):                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | Katy Morsony; Stephen Green; Eric Borden; Marcel Hawiger | 2021-02-19 | 2021-02-24 | 2021-02-24 |     |     | System hardening: Cost detail                                | System hardening                          |
|     |     |       |     |           |               |              |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | a) PG&E notes that covered conductor installation 7.3.3.3 and undergrounding 7.3.3.16 are included within 7.3.3.3.17.1.  Please disaggregate system hardening by covered conductor, undergrounding, and all other activities, by providing all column entries for these three categories                                                                                                                                                                                                                                                                                                                                                                                                                                             |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | b) if PG&E cannot disaggregate the system hardening spending, please explain why PG&E does not separately track costs for undergrounding, covered conductor insallation, and other system hardening activities                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |                                                          |            |            |            |     |     |                                                              |                                           |
| 102 | 100 | TURN  | 016 | TURN-016  | 2             | TURN-016.2   | PG&E Excel data attachment, Table 12. Please compare the covered conductor initiative (7.3.3.17.1) with the similar SCE initiative (7.3.3.3.1). PG&E used “line miles” while SCE used “miles of covered conductor.” Please explain whether PG&E converted some alternative unit(s) to obtain “line miles.” If yes, please explain the calculations used for the conversion and provide the original base units used for the conversion for each relevant year.                                                                                                                                                                                                                                                                       | Katy Morsony; Stephen Green; Eric Borden; Marcel Hawiger | 2021-02-19 | 2021-02-24 | 2021-02-24 |     |     | Covered conductor: Unit of measure clarification             | Covered conductor                         |
| 103 | 101 | TURN  | 016 | TURN-016  | 3             | TURN-016.3   | PG&E Excel data attachment, Table 12, initiative 7.3.3.6 (Distribution pole replacement): Please note that PG&E used “line miles” while SCE used “# of pole remediations” as the units. Please explain whether PG&E converted some alternative units to obtain “line miles.” If yes, please explain the calculations used for the conversion and provide the original base units used for the conversion for each relevant year                                                                                                                                                                                                                                                                                                      | Katy Morsony; Stephen Green; Eric Borden; Marcel Hawiger | 2021-02-19 | 2021-02-24 | 2021-02-24 |     |     | Distribution pole replacement: Unit of measure clarification | Distribution pole replacement             |
| 104 | 102 | WSD   | 006 | WSD-006   | 1             | WSD-006.1    | Split recovered spend by activity in HFTD and total activity spend                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | Ryan Arba                                                | 2021-02-18 | 2021-02-23 | 2021-02-22 | 1.0 |     | Activity spend: Additional detail                            | Activity spend                            |
| 105 | 103 | WSD   | 006 | WSD-006   | 2             | WSD-006.2    | Given changes in WMP activity spending, report planned spend as detailed in the 2020 WMP under the reporting system of the 2021 WMP                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | Ryan Arba                                                | 2021-02-18 | 2021-02-23 | 2021-02-22 |     |     | Activity spend: Updating reporting system                    | Activity spend                            |
| 106 | 104 | CalPA | 040 | CalPA-040 | 1             | CalPA-040.1  | In attachment 7.3.3_RSE_Input_Template_EO_WLDFR.xlsm, on the worksheet “1-Program Exposure,” PG&E lists the 2021 program exposure for program 7.3.3.5 “Crossarm maintenance, repair, and replacement” as 100%. Page (P.) 481 of PG&E’s 2021 WMP states, “PG&E conducts…bi-annual patrols in rural areas.” This appears to suggest that the program exposure in any given year should be 50%. a. Please explain this apparent discrepancy. b. Please provide a corrected version of this spreadsheet that corrects program exposure figures and RSE calculations wherever needed. Highlight any changed cells.                                                                                                                        | Alan Wehrman; Tyler Holzscuh; Aaron Louie; Carolyn Chen  | 2021-02-19 | 2021-03-01 | 2021-03-01 |     |     | Initiative 7.3.3.5 (Crossarm maintenance): Additional detail | Initiative 7.3.3.5 (Crossarm maintenance) |
| 107 | 105 | CalPA | 040 | CalPA-040 | [Target Cell] | CalPA-040.2  | P. 315 of PG&E’s 2021 WMP describes its Distribution, Transmission, and Substation: Fire Action Schemes and Technology (DTS-FAST) initiative. Per Table PG&E-7.1-3 New or Emerging Technologies on p. 303, this program is projected to cost $30 million in 2021.                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | Alan Wehrman; Tyler Holzscuh; Aaron Louie; Carolyn Chen  | 2021-02-19 | 2021-02-24 | 2021-02-24 |     |     | DTS-Fast: RSE detail                                         | DTS-Fast                                  |
|     |     |       |     |           |               |              | a. Please explain why PG&E did not estimate an RSE score for DTS-FAST.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |                                                          |            |            |            |     |     |                                                              |                                           |
| 108 | 106 | CalPA | 040 | CalPA-040 | 3             | CalPA-040.3  | P. 65 of PG&E’s 2021 WMP includes an explanation for PG&E’s estimate of the failure rates for Priority A and B tags. These estimated failure rates are used in attachment 7.3.4_RSE_Input_Template_EO_WLDFR.xlsm to estimate the effectiveness of PG&E’s Asset Management and Inspections programs.                                                                                                                                                                                                                                                                                                                                                                                                                                  | Alan Wehrman; Tyler Holzscuh; Aaron Louie; Carolyn Chen  | 2021-02-19 | 2021-03-01 | 2021-03-01 |     |     | Inspection tags: Failure rates                               | Inspection tags                           |
|     |     |       |     |           |               |              | a. State the basis of PG&E’s assumption that Priority A tags would fail within 60 days without remediation.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | b. State the basis of PG&E’s assumption that Priority B tags would fail within 227.5 days without remediation.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | c. Please list all other methods PG&E has considered for estimating the effectiveness of Asset Management and Inspection programs.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | d. Has PG&E used observed failure rates for various asset types to inform its estimates of the expected time to failure for electric corrective tags resulting from asset inspections? If so, please describe how.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | e. Does PG&E have plans to change its method of estimating failure rates and program effectiveness for Asset Management and Inspections initiatives?                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | f. If the answer to part (e) is yes, please explain the types of changes under consideration and the likely timeframe for implementation.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                                                          |            |            |            |     |     |                                                              |                                           |
| 109 | 107 | CalPA | 040 | CalPA-040 | 4             | CalPA-040.4  | P. 65 of PG&E’s 2021 WMP includes an explanation for PG&E’s estimate of the failure rates for Priority A and B tags. PG&E calculates a failure rate of about 84% for Priority A tags, then states, “This was conservatively reduced to 70 percent after review with the PG&E team.” PG&E calculates a failure rate of about 38% for priority B tags, then states, “This was adjusted to 50 percent after review with the PG&E team.”                                                                                                                                                                                                                                                                                                 | Alan Wehrman; Tyler Holzscuh; Aaron Louie; Carolyn Chen  | 2021-02-19 | 2021-03-01 | 2021-03-01 |     |     | Inspection tags: Failure rates                               | Inspection tags                           |
|     |     |       |     |           |               |              | a. Please explain PG&E’s justification for lowering the estimated failure rate for Priority A tags and provide any available evidence to support the revised failure rate.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | b. Please explain PG&E’s justification for increasing the estimated failure rate for Priority B tags and provide any available evidence to support the revised failure rate.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | c. Please explain why PG&E made adjustments in the estimated failure rates of Priority A and B tags in different directions (i.e. lowering the estimated failure rate for Priority A tags from the calculated value, while raising the estimated failure rate for Priority B tags from the calculated value).                                                                                                                                                                                                                                                                                                                                                                                                                        |                                                          |            |            |            |     |     |                                                              |                                           |
| 110 | 108 | CalPA | 040 | CalPA-040 | 5             | CalPA-040.5  | In attachment 7.3.3_RSE_Input_Template_EO_WLDFR.xlsm, on the worksheet “Summary of Programs,” PG&E lists the effectiveness as 90% for the following programs:                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | Alan Wehrman; Tyler Holzscuh; Aaron Louie; Carolyn Chen  | 2021-02-19 | 2021-02-24 | 2021-02-24 |     |     | RSE Calculations: Effectiveness detail                       | RSE Calculations                          |
|     |     |       |     |           |               |              | 7.3.3.1_Capacitor maintenance and replacement program                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | 7.3.3.4_Covered conductor maintenance                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | 7.3.3.5_Crossarm maintenance, repair, and replacement                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | 7.3.3.6_Distribution pole replacement and reinforcement, including with composite poles                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | 7.3.3.10_Maintenance, repair, and replacement of connectors, including hotline clamps                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | 7.3.3.12.3_Other corrective action                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | 7.3.3.13_Pole loading infrastructure hardening and replacement program based on pole loading assessment program                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | 7.3.3.14_Transformers maintenance and replacement                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | Under both “Effectiveness %” and “Justification for Effectiveness %” for each of these programs, PG&E states, “Likelihood of ignition due to Equipment Failure of [equipment] – 90%.”                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | a. Please confirm whether the statement above indicates a 90% effectiveness in addressing the likelihood of ignition due to equipment failure.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | b. If the answer to part (a) is yes, please state the basis of your estimate of a 90% effectiveness for each of the above programs.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | c. Please confirm whether the statement above indicates a 90% likelihood of ignition in the event that a given piece of equipement fails.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | d. If the answers to parts (a) and (c) are both yes, please explain how a 90% likelihood of ignition due to equipment failure corresponds to 90% effectiveness.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | e. If the answer to part (a) is yes, state the basis of PG&E’s representation that each of the above programs is equally effective.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | f. If the answer to part (c) is yes, state the basis of PG&E’s indication that the likelihood of ignition is the same for all of the above types of equipment.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | g. If the answers to parts (a) and (c) are both no, please explain the meaning of “Justification for Effectiveness %” and “Likelihood of ignition due to Equipment Failure of [equipment] – 90%.”                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                                          |            |            |            |     |     |                                                              |                                           |
| 111 | 109 | CalPA | 040 | CalPA-040 | 6             | CalPA-040.6  | In attachment 7.3.5_RSE_Input_Template_EO_WLDFR.xlsm, on the worksheet “Summary of Programs,” under “Justification for Effectiveness %” for program 7.3.5.2 “Detailed inspections of vegetation around distribution electric lines and equipment,” PG&E states, “Assumed the probability of untrimmed tree causing an outage in Distribution = 70%.” State the basis of this assumption.                                                                                                                                                                                                                                                                                                                                             | Alan Wehrman; Tyler Holzscuh; Aaron Louie; Carolyn Chen  | 2021-02-19 | 2021-02-24 | 2021-02-24 |     |     | RSE Calculations: Effectiveness detail                       | RSE Calculations                          |
| 112 | 110 | CalPA | 040 | CalPA-040 | 7             | CalPA-040.7  | In attachment 7.3.5_RSE_Input_Template_EO_WLDFR.xlsm, on the worksheet “Summary of Programs,” under “Justification for Effectiveness %” for program 7.3.5.8 “LiDAR inspections of vegetation around transmission electric lines and equipment,” PG&E states,                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | Alan Wehrman; Tyler Holzscuh; Aaron Louie; Carolyn Chen  | 2021-02-19 | 2021-02-24 | 2021-02-24 |     |     | RSE Calculations: Effectiveness detail                       | RSE Calculations                          |
|     |     |       |     |           |               |              | “The probability of untrimmed tree causing contact with the conductor in Transmission depends on the type of detection. For UCDs probability = 100%. For trees with critical grow-in potential, probability = 90%. For trees with critical fall-in potential, probability = 2%.”                                                                                                                                                                                                                                                                                                                                                                                                                                                     |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | a. Define “UCD.”                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | b. State the basis of this assumption: “For UCDs probability = 100%.”                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | c. State the basis of this assumption: “For trees with critical grow-in potential, probability = 90%.”                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | d. State the basis of this assumption: “For trees with critical fall-in potential, probability = 2%.”                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                                          |            |            |            |     |     |                                                              |                                           |
| 113 | 111 | CalPA | 040 | CalPA-040 | 8             | CalPA-040.8  | In attachment 7.3.5_RSE_Input_Template_EO_WLDFR.xlsm, on the worksheet “Summary of Programs,” under “Justification for Effectiveness %” for program 7.3.5.15 “Remediation of at-risk species,” PG&E states:                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | Alan Wehrman; Tyler Holzscuh; Aaron Louie; Carolyn Chen  | 2021-02-19 | 2021-02-24 | 2021-02-24 |     |     | RSE Calculations: Effectiveness detail                       | RSE Calculations                          |
|     |     |       |     |           |               |              | “Vegetation Management Subject Matter Experts reviewed the reported causes of distribution outages, tied to results from the vegetation outage investigation reports from 2015-2019. Based on the current scope of the EVM program, SMEs applied the following estimates of mitigation effectiveness for the EVM program to different types of vegetation-related outage causes*. In the Wildfire risk bowtie these vegetation-related causes are listed as sub-drivers for vegetation driver. …                                                                                                                                                                                                                                     |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | *See M1 | Assumptions tab for the full list of vegetation outage causes and effectiveness percentages, along with justifications.”                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | a. Provide a copy of the referenced “M1 | Assumptions tab.”                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | b. State the basis of this estimate: “Where a tree grew into conductor, PG&E estimates that EVM will be 50% effective in mitigating similar outages in the future.”                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | c. State the basis of this estimate: “Where the branch that caused the outage was overhanging, PGE estimates 90% effectiveness.”                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | d. State the basis of this estimate: “Where the branch that caused the outage was not overhanging, … if branch distance to conductor was within 4 feet, PG&E estimates 90% effectiveness.”                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | e. State the basis of this estimate: “Where the branch that caused the outage was not overhanging, … if branch distance to conductor was 4-12 feet, PG&E estimates 50% effectiveness.”                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | f. State the basis of this estimate: “Where the branch that caused the outage was not overhanging, … if branch distance to conductor was greater than 12 feet, PG&E estimates 0% effectiveness.”                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | g. State the basis of these estimates: “Where a tree fell into the line, PG&E estimates the effectiveness of EVM measures based on the health of the tree: Dead - 0% effectiveness, No defect - 0% effectiveness, Slight defect - 50% effectiveness; Moderate/severe defect - 95% effectiveness.”                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | h. How do observed data on circuit-segments that have been treated with EVM (for example, data on faults, outages, or ignitions) inform PG&E’s estimates of the effectiveness of EVM?                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | i. Does PG&E have plans to modify its estimations of EVM effectiveness?                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | j. If the answer to part (h) is yes, please explain types of changes under consideration and the likely timeframe for implementation.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                                          |            |            |            |     |     |                                                              |                                           |
| 114 | 112 | CalPA | 040 | CalPA-040 | 9             | CalPA-040.9  | In attachment 7.3.4_RSE_Input_Template_EO_WLDFR.xlsm, on the worksheet “7.3.4.1 - Effectiveness,” the Work Scope listed in columns F, G, and H does not appear to align with statements in PG&E’s WMP. For Tier 2 + Zone 1, the Work Scope is listed as 33%. However, in Table 5.3-1 List and description of program targets, last 5 years, on p. 237 of PG&E’s 2021 WMP, under “7.3.4.1 – Distribution HFTD Inspections (poles),” PG&E states that 100% of Zone 1 will be inspected. Please explain this apparent discrepancy.                                                                                                                                                                                                      | Alan Wehrman; Tyler Holzscuh; Aaron Louie; Carolyn Chen  | 2021-02-19 | 2021-02-24 | 2021-02-24 |     |     | RSE Calculations: Clarification                              | RSE Calculations                          |
| 115 | 113 | CalPA | 040 | CalPA-040 | 10            | CalPA-040.10 | In attachment 7.3.5_RSE_Input_Template_EO_WLDFR.xlsm, on the worksheet “1-Program Exposure,” PG&E states that EVM is to be performed on 7% of HFTD miles every year from 2020-2025.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | Alan Wehrman; Tyler Holzscuh; Aaron Louie; Carolyn Chen  | 2021-02-19 | 2021-02-24 | 2021-02-24 |     |     | RSE Calculations: Vegetation Management                      | RSE Calculations                          |
|     |     |       |     |           |               |              | a. Why did PG&E set its target for EVM work at 7% of HFTD miles per year? What is the reasoning for this target?                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | b. Does PG&E plan to perform EVM on a different 7% of HFTD miles each year, which would result in PG&E eventually performing EVM across all HFTD miles over a period of approximately 14 years?                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | c. If the answer to part (b) is yes, please explain PG&E’s reasoning for this approach.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | d. If the answer to part (b) is no, please explain how PG&E will choose which 7% of HFTD miles to treat each year.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | e. Has PG&E already determined the 1800 target miles that will be treated with EVM in 2021?                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                                                          |            |            |            |     |     |                                                              |                                           |
| 116 | 114 | CalPA | 040 | CalPA-040 | 11            | CalPA-040.11 | In attachment 7.3.5_RSE_Input_Template_EO_WLDFR.xlsm, on the worksheet “Summary of Programs,” cell L21 states the benefit length for EVM to be, “30 Years for Branch related vegetation sub drivers, 1 Year for everything else.”                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | Alan Wehrman; Tyler Holzscuh; Aaron Louie; Carolyn Chen  | 2021-02-19 | 2021-02-24 | 2021-02-24 |     |     | RSE Calculations: Vegetation Management                      | RSE Calculations                          |
|     |     |       |     |           |               |              | Cell M21, “Justification for Benefit Length” states, “Once the EVM program establishes the radial clearances and branch overhangs, which applies to all branch related Sub-drivers the annual Vegetation control program maintains the clearances by trimming the growth.”                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | a. Define “branch related vegetation sub drivers.”                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | b. State the basis of PG&E’s estimate of a 30-year benefit life for branch-related vegetation sub-drivers.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                                          |            |            |            |     |     |                                                              |                                           |
| 117 | 115 | CalPA | 040 | CalPA-040 | 12            | CalPA-040.12 | P. 623 of PG&E’s 2021 WMP states, “In HFTD areas, PG&E’s Routine VM meets regulations [GO 95, Rule 35] requiring four feet (ft) radial clearance around overhead distribution lines.”                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | Alan Wehrman; Tyler Holzscuh; Aaron Louie; Carolyn Chen  | 2021-02-19 | 2021-02-24 | 2021-02-24 |     |     | RSE Calculations: Vegetation Management                      | RSE Calculations                          |
|     |     |       |     |           |               |              | a) Does PG&E’s routine VM program maintain wider clearances (beyond the regulatory minimum in GO 95, Rule 35) that have been established during prior EVM?                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                                          |            |            |            |     |     |                                                              |                                           |
|     |     |       |     |           |               |              | b) If so, how does PG&E ensure that workers performing Routine VM know where to maintain wider clearances and where to meet regulatory requirements as described on page 623?                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |                                                          |            |            |            |     |     |                                                              |                                           |



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