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SAN FRANCISCO

 

Robert A. Julian (SBN 99469) 

Cecily A. Dumas (SBN 111449) 

BAKER & HOSTETLER LLP 

1160 Battery Street, Suite 100 

San Francisco, CA 94111 

Telephone: 628.208.6434 

Facsimile: 310.820.8859 

Email: rjulian@bakerlaw.com 

Email: cdumas@bakerlaw.com 

Eric E. Sagerman (SBN 155496) 

Lauren T. Attard (SBN 320898) 

BAKER & HOSTETLER LLP

11601 Wilshire Boulevard 

Suite 1400 

Los Angeles, CA 90025 

Telephone: 310.820.8800 

Facsimile: 310.820.8859 

Email: esagerman@bakerlaw.com 

Email: lattard@bakerlaw.com 

Counsel for Official Committee of Tort Claimants 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION 

-andPACIFIC GAS AND ELECTRIC 

COMPANY, 

 Debtors 

Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) 

(Jointly Administered) 

□ Affects PG& E Corporation 

□ Affects Pacific Gas and Electric Company 

■ Affects both Debtors 

*All papers shall be filed in the Lead Case, 

No. 19-30088 (DM) 

AMENDED REDACTED 

DECLARATION OF BRENT C. 

WILLIAMS IN SUPPORT OF 

OFFICIAL COMMITTEE OF TORT 

CLAIMANTS’ LIMITED JOINDER, 

OBJECTION AND COUNTER MOTION 

TO DEBTORS’ WILDFIRE 

ASSISTANCE PROGRAM MOTION 

(DKT. NO. 1777) 

Date: May 22, 2019 

Time: 9:30 a.m. (Pacific Time) 

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Case: 19-30088 Doc# 2120 Filed: 05/20/19 Entered: 05/20/19 17:28:02 Page 1 of

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1. I, Brent C. Williams, am a Managing Director and Co-Head of Lincoln's Special 

Situations Group at Lincoln Partners Advisors LLC (“Lincoln”), which has its principal office at 

500 West Madison Street, Suite 3900 Chicago, IL. I am authorized to execute this declaration on 

behalf of Lincoln. Unless otherwise stated in this declaration, I have personal knowledge of the 

facts set forth herein. 

2. I am making this declaration in support of the Official Committee of Tort Claimants’ 

Limited Joinder, Objection and Counter Motion (“Joinder”) to the Debtors’ Wildfire Assistance 

Program Motion (Dkt. No. 1777) (“Motion”). Capitalized terms used but not defined herein shall 

have the same meaning ascribed to them in the Motion. 

3. The victims who lost their homes in the 2017 and 2018 wildfires that are still in need 

of assistance include homeowners and renters that are either: a) uninsured or b) those that are 

insured but have either exhausted their insurance based on time or value, or have insufficient 

insurance to cover what is known as “Alternative Living Expenses” or other urgent needs (the 

“underinsured”). 

4. I believe the $100 million of proposed funding ($105 million, net of $5 million 

administrative costs) is inconsistent with historical practice and insufficient to even make a nominal 

distribution to the victims of the 2017 and 2018 wildfires. For example, assuming 15,000 

households asserted valid claims for this fund, that would imply only $6,667 would be provided to 

those families assuming they all received equal distributions. By way of reference, and pursuant to 

the 2015 Butte Fire, PG&E offered up to $50,000 to homeowners and up to $10,000 to renters 

(“2015 Butte Fire Program”). 

5. In order to better understand how the $100 million was quantified, my team provided 

a list of questions to the Debtors on Monday May 6, 2019. On Friday May 10, 2019 the Debtors 

responded to our questions, attached hereto as Exhibit C. Pursuant to their responses, the Debtors 

 

1

 “TCC Information Request: Wildfire Assistance Program Motion; Responses to Request Dated 5.6.19.” 

REDACTED

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believe that the $105 million is an amount that will “provide eligible wildfire claimants a reasonable 

opportunity to receive meaningful assistance for temporary housing and other urgent needs . . . .” 

The Debtors have not quantified what the projected payout by household and/or individual is 

estimated to be. The Debtors have simply deferred all of these important facts and datapoints to 

the “to-be-determined” Administrator of the Wildfire Assistance Program. 

6. In their Motion, the Debtors do not mention whether they believe that the $105 

million is adequate to provide “some relief” to the victims. Motion at 4:18. In their Motion, the 

Debtors have not quantified nor estimated the number of households or individuals that may be 

covered by the Wildfire Assistance Program. As evidenced by their Motion, it seems they have 

disclaimed all responsibility to the Administrator, including determination of Eligibility Criteria, 

and, to my knowledge, did not complete meaningful analysis or calculations to support the Motion. 

7. In order to properly structure the Wildfire Assistance Program and assess whether 

the funding will provide “some relief,” it is imperative that this data (at least, on a preliminary 

basis) be assessed and/or quantified by the Debtors. 

8. Based upon the Debtors’ Motion, coupled with my independent research and 

calculations, I believe the Wildfire Assistance Fund is underfunded. Further, the Debtors risk not 

being able to accommodate all of the victims with an appropriate distribution and / or could force 

the administrator to turn away thousands of victims while leaving thousands of others with only a 

short lifeline before additional emergency assistance is needed. 

9. Based upon my team’s calculations, to fund a Wildfire Assistance Program that 

accommodates all of the Alternative Living Expenses and other immediate needs for the victims, 

the amount of the necessary funding would need to exceed $480 million based upon the Debtors’ 

past practices (Exhibit A). 

10. My team also ran an alternative scenario (Exhibit B), which estimated the monthly 

hardship living expenses for the victims. This scenario estimated the necessary funding at 

approximately $313 million. 

11. The necessary funding estimates are based upon publicly available claimant, 

homeowner, and insurance statistics. Lincoln’s analysis considered the following data: 

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a. Households Claim Pool: The victims include individuals who lost their homes 

in the 2017 North Bay Fires and the 2018 Camp Fire. Information provided by 

Cal Fire (JP Morgan Report)2 and the Debtors3 was used to determine the total 

number of residential households lost that could be eligible for assistance under 

the Wildfire Assistance Program. Cal Fire (JP Morgan Report) indicated total 

residential households lost in the North Bay Fires were 6,393 while the Debtors’ 

Wildfire Assistance Program Motion reported that 13,972 households were lost 

in the 2018 Camp Fire, or 20,365 residences lost in total. 

b. Homeowner vs. Renter Pool: The lost homes included both homeowners and 

renters, which would be covered under the Wildfire Assistance Program. 

However, as demonstrated in the 2015 Butte Fire Program, homeowners and 

renters would likely experience different levels of losses, insurance coverage, 

and requirements under Alternative Living Expenses. As such, 2018 Census data 

from Butte County4 and Sonoma County5 were utilized to determine the 

percentage of owner-occupied homes, which indicated 59.0% and 60.3% 

respectively. 

c. Homeowners vs Renters Claimants: The Census and CAL fire data was used 

to determine the number of lost households for renters and homeowners, which 

estimated lost households of 12,098 for homeowners and 8,267 for renters, or 

20,365 in total. 

d. Uninsured Claimants Pool: The Wildfire Assistance Program was established 

to aid victims who are either uninsured or underinsured by their existing 

insurance policies. To determine the number of uninsured households, a 2017 

survey from United Policyholders6 was used, which indicated 4.2% of 

households in California were uninsured. Additionally, a 2014 press release 

 

2

 JP Morgan Report: “PG&E Corp: Looking for a Grand Bargain in Bankruptcy", dated January 18, 2019 

3

 Debtors’ Wildfire Assistance Program Motion (Dkt. No. 1777) 

4

 https://www.census.gov/quickfacts/buttecountycalifornia 

5

 https://www.census.gov/quickfacts/sonomacountycalifornia 

6

 http://www.uphelp.org/sites/default/files/blog/2017hosurveyca.pdf 

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from the Insurance Information Institute7 indicated 63% of renters were 

uninsured. Both estimates are likely conservative given the higher cost of 

insurance policies in areas that are prone for natural disasters, such as wildfires 

in Northern California. 

e. Uninsured Homeowners and Renters Claimants: By utilizing the publicly 

available uninsured households data, Lincoln estimated that 507 homeowners 

and 5,208 renters were uninsured. 

f. Underinsured Claimants Pool: To determine the number of underinsured 

households, Lincoln used a United Policyholders survey from the 2017 North 

Bay fires8, which indicated that “66% of survey respondents who know if they 

have enough insurance to cover the cost of repairing, replacing or rebuilding 

their home, reported being underinsured.” These underinsured survey results 

have been cited in many publications and even referenced at a state legislative 

committee hearing9. In fact, these estimates are low as compared to a number of 

TCC claimants that were polled. 

g. Underinsured Claimants: As a result, Lincoln estimated that 7,650 

homeowners and 2,019 renters were underinsured. 

h. Total Pool of Eligible Wildfire Claimants: In total, Lincoln estimated that 

15,384 households would be eligible to receive assistance under the Wildfire 

Assistance Program (8,157 homeowners and 7,227 renters). 

i. Wildfire Assistance Program Funding: To determine the total Wildfire 

Assistance Program funding required, Lincoln utilized two scenarios to estimate 

the funding per eligible household: 

i. Scenario 1 (Exhibit A): Lincoln utilized the Debtors’ prior practices 

during the 2015 Butte Fire Program of $50,000 for homeowners and 

$10,000 for renters. These values indicated necessary funding of $480 

 

7

 https://www.iii.org/press-release/number-of-renters-is-on-the-rise-but-few-of-them-have-insurance-092214. 

8

 https://www.uphelp.org/sites/default/files/attachments/north_bay_fires_12_month_survey_report_v1.pdf. 

9

 http://www.ktvu.com/news/joint-hearing-addresses-insurance-concerns-from-north-bay-fire-victims. 

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million or $31,210 per household. Detailed calculations are provided in 

Exhibit A. 

ii. Scenario 2 (Exhibit B): Lincoln estimated the monthly living expenses 

for the victims by utilizing the U.S. General Service Administration 

GSA als in Sacramento and 

the broader California market. Lincoln also considered publicly available 

apartment and housing rental rates in the Chico, California area. The 

monthly GSA and rental costs were averaged and multiplied by six 

months, which indicated approximately $29,500 of funding per 

household. These estimates were only used for the homeowners, while 

the renter funding remained at $10,000 per household. These values 

indicated necessary funding of $313 million or $20,340 per household. 

Detailed calculations are provided in Exhibit B. 

12. As established by the analysis above, the minimum amount of funding to achieve 

the Program Objectives is at least $250 million (implying, on average, only ~$16,250 per 

household) provided that the amount is subject to incremental replenishment. 

I declare under penalty of perjury under the laws of the United States of America that the foregoing 

is true and correct. Executed on May 15, 2019. 

Brent C. Williams

 

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Exhibit A 

 

Household Lost Insured Cash For Total Assisted Breakout[a],[b] Households[c],[d] % Households Households % Households Total % of Lost Total Assistance[h] Funds 2017 Fires Homeowners 60.3% 3,855 4.2% 162 3,693 66.0% 2,438 2,599 67.4% 50,000 $ 129,960,209 $ 

Renters 39.7% 2,538 63.0% 1,599 939 66.0% 620 2,219 87.4% 10,000 22,187,380 Total 100.0% 6,393 27.5% 1,760 4,633 66.0% 3,057 4,818 75.4% 31,579 152,147,588 2018 Camp Fire

Homeowners 59.0% 8,243 4.2% 345 7,898 66.0% 5,213 5,558 67.4% 50,000 277,906,671 Renters 41.0% 5,729 63.0% 3,609 2,120 66.0% 1,399 5,008 87.4% 10,000 50,078,722 Total 100.0% 13,972 28.3% 3,954 10,018 66.0% 6,612 10,566 75.6% 31,042 327,985,393 Total Homeowners 59.4% 12,098 4.2% 507 11,592 66.0% 7,650 8,157 67.4% 50,000 407,866,879 Renters 40.6% 8,267 63.0% 5,208 3,059 66.0% 2,019 7,227 87.4% 10,000 72,266,101 Total 100.0% 20,365 28.1% 5,715 14,650 66.0% 9,669 15,384 75.5% 31,210 $ 480,132,981 $ 

a. Owner-occupied households for the 2017 Fires based on U.S. Census Bureau QuickFacts: Sonoma County, California V2018

b. Owner-occupied households for the 2018 Camp Fire based on U.S. Census Bureau QuickFacts: Butte County, California V2018

c. Total lost households for the 2017 Fires based on JP Morgan Report: "PG&E Corp. Looking for a Grand Bargain in Bankruptcy" January 18, 2019 

d. Total lost households for the 2018 Camp Fire based on the Debtors' Wildfire Assistance Program Motion (Dkt. No. 1777)

e. Uninsured homeowners based on United Policyholders 2017 California Home Insurance Survey 

f. Uninsured renters based on Insurance Information Institute press release September 22, 2014 "Number of Renters is on the Rise - But Few of Them Have Insurance" 

g. Underinsured homeowners and renters based on United Policyholders 2017 North Bay Fires - 12 Month Survey 

h. Cash for Assistance based on the 2015 Butte Fire PG&E assistance offer to homeowners and renters provided by the Debtors

Uninsured [e],[f] Underinsured[g] Total Uninsured & Underinsured

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Exhibit B 

 

Household Lost Insured Cash For Total Assisted Breakout[a],[b] Households[c],[d] % Households Households % Households Total % of Lost Total Assistance[h] Funds 2017 Fires Homeowners 60.3% 3,855 4.2% 162 3,693 66.0% 2,438 2,599 67.4% 29,500 $ 76,676,523 $ 

Renters 39.7% 2,538 63.0% 1,599 939 66.0% 620 2,219 87.4% 10,000 22,187,380 Total 100.0% 6,393 27.5% 1,760 4,633 66.0% 3,057 4,818 75.4% 20,520 98,863,903 2018 Camp Fire

Homeowners 59.0% 8,243 4.2% 345 7,898 66.0% 5,213 5,558 67.4% 29,500 163,964,936 Renters 41.0% 5,729 63.0% 3,609 2,120 66.0% 1,399 5,008 87.4% 10,000 50,078,722 Total 100.0% 13,972 28.3% 3,954 10,018 66.0% 6,612 10,566 75.6% 20,258 214,043,658 Total Homeowners 59.4% 12,098 4.2% 507 11,592 66.0% 7,650 8,157 67.4% 29,500 240,641,459 Renters 40.6% 8,267 63.0% 5,208 3,059 66.0% 2,019 7,227 87.4% 10,000 72,266,101 Total 100.0% 20,365 28.1% 5,715 14,650 66.0% 9,669 15,384 75.5% 20,340 $ 312,907,560 $ 

a. Owner-occupied households for the 2017 Fires based on U.S. Census Bureau QuickFacts: Sonoma County, California V2018

b. Owner-occupied households for the 2018 Camp Fire based on U.S. Census Bureau QuickFacts: Butte County, California V2018

c. Total lost households for the 2017 Fires based on JP Morgan Report: "PG&E Corp. Looking for a Grand Bargain in Bankruptcy" January 18, 2019 

d. Total lost households for the 2018 Camp Fire based on the Debtors' Wildfire Assistance Program Motion (Dkt. No. 1777)

e. Uninsured homeowners based on United Policyholders 2017 California Home Insurance Survey 

f. Uninsured renters based on Insurance Information Institute press release September 22, 2014 "Number of Renters is on the Rise - But Few of Them Have Insurance" 

g. Underinsured homeowners and renters based on United Policyholders 2017 North Bay Fires - 12 Month Survey 

h. Cash for Assistance based on the local and state 2019 US GSA per diem rates in California for lodging and meals as well as publicly available home/apartment rental data for Chico, CA

Uninsured [e],[f] Underinsured[g] Total Uninsured & Underinsured

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Exhibit C 

TCC Information Request: 

Wildfire Assistance Program Motion 

Responses to Request Dated 5.6.19 

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TCC Information Request 

Wildfire Assistance Program Motion

Responses to Request dated 5.6.19

1

This Presentation includes both public and non-public information. Information labeled “Confidential” or “Professionals’ Eyes 

Only” are subject to the terms of each Professional Advisor’s confidentiality agreement or committee by-laws, as applicable.

PCG SECURE DATAROOM; NO 

UNAUTHORIZED USE

Naeem Muscatwalla

Lincoln International

May 10, 2019 12:36

Case: 19-30088 Doc# 2120 Filed: 05/20/19 Entered: 05/20/19 17:28:02 Page 10

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2

TCC Information Request - Wildfire Assistance 

Program Motion: Request as of 5.6.19

Highly Confidential – Professionals’ Eyes Only

Request # Diligence Request Response

1 How was the $105 million quantified and ultimately 

determined for the Wildfire Assistance Fund ("Fund") 

(including any / all analysis)?

PG&E believes that $105 million is an amount that will provide eligible wildfire 

claimants a reasonable opportunity to receive meaningful assistance for temporary 

housing and other urgent needs and to cover the administrative costs of the Fund.

2 Provide number of household(s) and individual victim(s) (for 

each of the 2017 and 2018 wildfires) that are estimated to be 

covered under the Fund

Any estimate of the number of households and individuals that may be covered by the 

Wildfire Assistance Program will depend greatly on how the Administrator, in his or her 

discretion, determines to implement the program and address questions such as the 

types of expenses covered by the program and who is eligible to participate in the 

program. Accordingly, the Debtors do not believe it is appropriate, or possible, for the 

Debtors to provide an estimate. To the extent that the Official Committee of Tort 

Claimants seeks this information, the request should be made of the Administrator 

after he/she has established guidelines for how the program would be implemented. 

3 What is the projected payout by household and/or by victim? 

Has the Debtor estimated or forecasted a minimum payout 

(by individual)?

Any estimate of the projected payout by household and/or by individual will depend 

greatly on how the Administrator, in his or her discretion, determines to implement the 

Wildfire Assistance Program and address questions such as the types of expenses 

covered by the program and who is eligible to participate in the program. Accordingly, 

the Debtors have not forecasted a minimum payout.

4 How does this Fund compare to prior hardship funds, such as 

the 2015 Butte Fire, in terms of payout(s) by household or by 

claimant?

As noted above, payout by household or claimant under the Wildfire Assistance 

Program cannot be estimated at this time. Accordingly, any comparison of payouts 

with prior hardship funds is not possible. 

The Debtors do not believe the Butte Fire and San Bruno programs, which are different 

in scope and design from the Wildfire Assistance Program, are relevant for purposes of 

analyzing the Wildfire Assistance Approval Motion. Notwithstanding this, the Debtors 

provide the following brief summary: With regard to the 2015 Butte Fire, PG&E offered 

up to $50,000 to homeowners and up to $10,000 to renters of homes destroyed in the 

Butte Fire who (i) were in urgent need of financial assistance to cover costs, including 

temporary housing, vehicle rental, or replacement of household items, and (ii) did not 

have insurance. The assistance was provided by PG&E’s Law-Claims organization. 

With regard to the 2010 San Bruno accident, PG&E offered residents in the impacted 

area $15,000, $25,000, or $50,000 per household depending on the extent of damaged 

incurred.

PCG SECURE DATAROOM; NO 

UNAUTHORIZED USE

Naeem Muscatwalla

Lincoln International

May 10, 2019 12:36

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3

TCC Information Request - Wildfire Assistance 

Program Motion: Request as of 5.6.19

Highly Confidential – Professionals’ Eyes Only

Request # Diligence Request Response

5 How was the eligibility criteria determined for the 2015 fund? 

Were there minimum payout(s) assumed in structuring the 

fund?

See the answer to question 4 above.

6 What was the total dollar amount that the Debtor's funded for 

the 2015 Butte Fire hardship fund? Please detail by: (1) 

Renters versus households, (2) Total number of renters and 

total number of households and (3) Total amount paid to each. 

Please provide detail(s) of the total funds paid.

 

7 What percentage of the total structures/residences destroyed 

in the 2015 Butte Fires received hardship funds?

See the answer to 6 above.

8 Does the Debtor anticipate payout(s) before the proposed Bar 

Date?

PG&E’s hope and desire is that the Wildfire Assistance Program be established and 

available to distribute funds as soon as possible, but the timing of both events depends 

on factors outside of PG&E’s control, including when the Bankruptcy Court approves the 

motion, when an Administrator will be appointed and, once an Administrator is 

appointed, when the Administrator, in his or her discretion, determines to start 

distributing funds from the Wildfire Assistance Program.

9 What section of the DIP credit agreement and what line item 

of the DIP Budget do the Debtors' contend the $105 million 

funding complies with (confirm: operations and maintenance)? 

Did the DIP Lenders consent to the $105 million funding? What 

consent rights do they have for a Motion like this?

The wildfire assistance program is permitted by Section 7.5(k) of the DIP credit 

agreement, but we note that the DIP credit agreement has no budget compliance or 

similar covenant. The wildfire assistance program was however included in the line item 

“Operations and Maintenance” for the week ending 05/25/19 in the revised 13 week 

cash flow forecast that AlixPartners presented to Lincoln Financial on May 1. Because 

the wildfire assistance program is permitted under the DIP credit agreement, the DIP 

lenders' consent is not required for the $105 million funding.

10 Notwithstanding what is in the Motion, what is the anticipated 

timeline of payout(s) under the Fund?

PG&E’s hope and desire is that the Wildfire Assistance Program be available to 

distribute funds as soon as possible, but the timing depends on factors outside of PG&E’s 

control, including when the Bankruptcy Court approves the motion, when an 

Administrator will be appointed and, once an Administrator is appointed, when the 

Administrator, in his or her discretion, determines to start distributing funds from the 

Wildfire Assistance Program.

PCG SECURE DATAROOM; N

UNAUTHORIZED USE

Naeem Muscatwalla

Lincoln International

May 10, 2019 12:36

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TCC Information Request - Wildfire Assistance 

Program Motion: Request as of 5.6.19

Highly Confidential – Professionals’ Eyes Only

Request # Diligence Request Response

11 Will the Debtor recommend individual(s) for the Administrator 

position?

PG&E has provided the names of three individuals for the Administrator position and 

will continue to engage counsel to the Official Committee of Tort Claimants and counsel 

to the Official Committee of Unsecured Creditors regarding a suitable person to be 

appointed as the Administrator. If there is an agreement among the parties as to the 

Administrator, PG&E will file a notice with the Court disclosing the identity and 

qualifications of the person selected to serve as Administrator. If the parties cannot 

agree upon an appropriate individual to serve as the Administrator, PG&E will file a 

motion seeking the appointment of an appropriate individual as the Administrator.

12 Will the Debtor have unfettered access to the materials / 

discussions / claims that the Administrator will have regarding 

the individual victims?

As described in the Motion seeking approval of the Wildfire Assistance Fund, the 

Administrator must keep adequate administrative and financial records of the program, 

including a record of to whom disbursements from the fund are made and in what 

amounts. PG&E and the Committees may inspect the program’s records upon request. 

 In addition, the Administrator shall file with the Bankruptcy Court and serve on the 

Debtors and the Committees quarterly reports as described in the Motion on page 10.

13 What will the Debtor's involvement be on a day-to-day basis 

with the Administrator?

PG&E will not be involved on a day-to-day basis with the Administrator. The 

Administrator will be responsible, in his or her discretion, for the day-to-day 

implementation of the Wildfire Assistance Program and the distribution of funds in a fair 

and equitable manner. 

PCG SECURE DATAROOM; NO 

UNAUTHORIZED USE

Naeem Muscatwalla

Lincoln International

May 10, 2019 12:36

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