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GREENE RADOVSKY 

MALONEY SHARE &

HENNIGH LLP

FOUR EMBARCADERO 

CTR, SUITE 4000 

SAN FRANCISCO, CA 

94111 

UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION, 

 -andPACIFIC GAS & ELECTRIC COMPANY, 

 Debtors, 

☐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) 

 Case No.: 19-30088-DM 

Chapter 11 

STATEMENT OF CITY AND COUNTY 

OF SAN FRANCISCO IN SUPPORT OF 

MOTION BY TURN FOR 

APPOINTMENT OF OFFICIAL 

COMMITTEE OF RATEPAYER 

CLAIMANTS PURSUANT TO 11 U.S.C. 

§§ 1102(a)(2), 105(a) 

DATE: May 8, 2019 

TIME: 9:30 am 

PLACE: Courtroom 17 

450 Golden Gate Avenue, 16th Fl.

San Francisco, California 

JUDGE: Hon. Dennis Montali 

RELATED DOCKET NOS: 1324 

/// 

 The City and County of San Francisco (“San Francisco”) in the above-captioned chapter 11 

cases of Pacific Gas and Electric Company (the “Utility”) and PG&E Corporation (“PG&E Corp.”

EDWARD J. TREDINNICK (#84033) 

GREENE RADOVSKY MALONEY 

 SHARE & HENNIGH LLP

Four Embarcadero Center, Suite 4000 

San Francisco, California 94111-4106 

Telephone: (415) 981-1400 

Facsimile: (415) 777-4961 

E-mail: etredinnick@greeneradovsky.com 

Attorneys for Creditor, 

City and County of San Francisco 

Case: 19-30088 Doc# 1650 Filed: 04/24/19 Entered: 04/24/19 13:28:07 Page 1 of

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MALONEY SHARE &

HENNIGH LLP

FOUR EMBARCADERO 

CTR, SUITE 4000 

SAN FRANCISCO, CA 

94111 

and, together with the Utility, the “Debtors”), hereby submits this statement in support of the Motion 

by TURN for Appointment of Official Committee of Ratepayer Claimants Pursuant to 11 U.S.C. §§ 

1102(a)(2), 105(a) (the “TURN Motion”) [Docket No. 1324]. 

Pacific Gas and Electric Company is the investor-owned utility that serves San Francisco. The 

citizens of San Francisco are impacted by the Utility’s rates regardless of whether they take gas and 

electric service solely from the Utility, or are customers of San Francisco’s publicly-owned utility or 

San Francisco’s community choice aggregation program (“CCA”), CleanPowerSF. Therefore, San 

Francisco strongly supports an official committee to advocate on behalf of ratepayers. 

San Francisco agrees with TURN that ratepayers represent unique interests in these 

proceedings. Indeed, while San Francisco in no way intends to minimize the critical interests of fire 

victims and their communities (and San Francisco is pleased that a committee has been formed to 

represent their interests), ratepayers likely represent one of the largest interests in terms of the longterm monetary impacts of the Utility’s bankruptcy. That is because of the Utility’s ability to 

potentially recover its costs, including claims paid to other creditors, by passing them on to ratepayers 

– this is a very different posture than other creditors in these bankruptcy cases. Given these unique 

interests, the two current official committees representing general unsecured creditors and fire 

victims/tort claimants, as presently constituted, do not adequately represent ratepayers. 

In support of the TURN Motion, San Francisco notes the extraordinary nature of these 

bankruptcy cases. This is the second time in the past 18 years that the Utility has declared bankruptcy. 

As a result of the Utility’s prior bankruptcy, ratepayers paid costs in the billions of dollars through 

increased rates. The Utility’s customers already pay some of the highest rates in the country and the 

current bankruptcy cases will likely result in even higher rates. The Utility has already requested an 

increase in revenue for 2020 of $1.2 billion. The possible effects on ratepayers are substantial, longterm financial burdens that the Utility’s customers could bear for many years to come. 

San Francisco also agrees with TURN that a ratepayer committee should represent a broad 

diversity of ratepayer interests. In that regard, San Francisco suggests that, if formed, the committee 

includes ratepayers from communities that have been, or are in danger of being, affected by 

catastrophic wildfires. The looming threat of wildfires gives such ratepayers a perspective that is 

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GREENE RADOVSKY 

MALONEY SHARE &

HENNIGH LLP

FOUR EMBARCADERO 

CTR, SUITE 4000 

SAN FRANCISCO, CA 

94111 

markedly different from that of consumer groups that regularly represent ratepayers before the 

California Public Utilities Commission. The committee should also include CCA ratepayers, who are 

uniquely situated among the Utility’s other ratepayers. Although they receive competitive electric 

generation supply from their local communities, they also pay for the Utility’s recovery of abovemarket procurement costs and receive other services, such as transmission and distribution, from the 

Utility. 

To be clear San Francisco does not intend to participate on a ratepayers committee should the 

Court direct the U.S. Trustee to appoint one, due to San Francisco’s serious interest in negotiating 

with the Utility to acquire electric infrastructure assets in the City and County, subject ultimately to 

approval of this Court. San Francisco is currently undertaking a due diligence and feasibility analysis 

to inform its decision about making an offer. But San Francisco urges the appointment of an official 

ratepayers committee to ensure that ratepayers’ distinct interests have a formal avenue to be 

effectively and efficiently represented in these bankruptcy cases. 

 Respectfully submitted, 

Dated: April 24, 2019 GREENE RADOVSKY MALONEY 

SHARE & HENNIGH LLP 

By: _____/s/ Edward Tredinnick_________________ 

 Edward J. Tredinnick 

 Attorneys for Creditor, 

 City and County of San Francisco 

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