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LOCKE LORD LLP 

Meagan S. Tom (SBN 273489) 

meagan.tom@lockelord.com 

101 Montgomery Street, Suite 1950 

San Francisco, CA 94104 

Telephone: (415) 318-8810 

Fax: (415) 676-5816 

Bradley C. Knapp (admitted pro hac vice) 

bknapp@lockelord.com 

601 Poydras Street, Suite 2660 

New Orleans, Louisiana 70130 

Telephone: (504) 558-5210 

Fax: (504) 910-6847 

W. Steven Bryant (admitted pro hac vice) 

sbryant@lockelord.com 

600 Congress Street, Suite 2200 

Austin, Texas 78701 

Telephone: (512) 305-4700 

Fax: (512) 305-4800 

Attorneys for Creditor 

International Brotherhood of Electrical Workers Local Union 1245 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION and PACIFIC GAS & 

ELECTRIC COMPANY 

Debtors 

_____ Affects PG&E Corporation 

_____ Affects Pacific Gas and Electric Company 

 X Affects both Debtors 

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CASE NO.: 19-30088 

Chapter 11 

(Lead Case) 

(JOINTLY ADMINISTERED) 

INTERNATIONAL 

BROTHERHOOD OF 

ELECTRICAL WORKERS, LOCAL 

UNION NO. 1245’S JOINDER TO 

JOINT MOTION OF THE 

OFFICIAL COMMITTEE OF 

TORT CLAIMANTS AND AD HOC 

COMMITTEE OF SENIOR 

UNSECURED NOTEHOLDERS TO 

Case: 19-30088 Doc# 4046 Filed: 10/01/19 Entered: 10/01/19 14:41:28 Page 1 of

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TERMINATE THE DEBTORS’ 

EXCLUSIVE PERIODS PURSUANT 

TO SECTION 1121(d)(1) OF THE 

BANKRUPTCY CODE 

Date: October 7, 2019 

Time: 1:30 PM 

Place: Courtroom 17, U.S. Bankruptcy 

Court, 16th Floor, 450 Golden Gate 

Avenue, San Francisco, California 

The International Brotherhood of Electrical Workers Local Union 1245 (“IBEW”) files this 

Joinder to the Joint Motion of the Official Committee of Tort Claimants and Ad Hoc Committee of 

Senior Unsecured Noteholders to Terminate the Debtors’ Exclusive Periods Pursuant to Section 

1121(d)(1) of the Bankruptcy Code (“Motion”) (Dkt. 3940). IBEW joins in the Motion and adds the 

following: 

I. Introduction 

The IBEW is a labor organization affiliated with the American Federal of Labor – Congress 

of Industrial Organizations. The IBEW represents approximately 20,000 gas and utility employees, 

including thousands of employees of Pacific Gas & Electric Company (“PG&E”), throughout 

California. IBEW members are responsible for building, maintaining, repairing, and operating 

PG&E’s natural gas and electric transmission and distribution systems and are therefore critical to 

PG&E’s ability to supply gas and electricity to approximately 16 million California residents. 

II. Joinder and Statement 

The IBEW continues to support plan competition and a termination of exclusivity in these 

cases. On July 16, 2019, the IBEW joined the prior request by the Ad Hoc Committee of Senior 

Unsecured Noteholders (“Noteholders”) to terminate exclusivity. (Dkt. No. 3012). At the time, the 

IBEW supported termination of exclusivity primarily out of its concern that PG&E did not appear 

capable of taking full advantage of the extraordinary legislative efforts that culminated in Assembly 

Bill 1054.1 As the Court is well-aware, that legislation created a going-forward wildfire fund that is 

1

 The text of AB 1054 may be accessed at the following link: 

http://leginfo.legislature.ca.gov/faces/billPdf.xhtml?bill_id=201920200AB1054&version=20190AB105495CHP

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intended to stabilize California’s electric utilities and provide relief to future fire victims and 

ratepayers.2 For PG&E to participate in this fund, these Bankruptcy Cases “must be resolved 

pursuant to a plan or similar document not subject to a stay,” the Court must determine that there is 

funding to pay pre-petition wildfire claims, and the California Public Utilities Commission 

(“CPUC”) must approve the reorganization plan and various other matters, all by June 30, 2020.3

This extremely tight deadline would be difficult to satisfy under the best of conditions. These are 

not the best of conditions. In the fleeting months since AB 1054 was enacted, PG&E has made too 

little progress—the lion’s share of which has come only as a result of pressure exerted upon PG&E 

by other concerned stakeholders—in developing a viable and potentially-confirmable plan of 

reorganization. Now, with just nine months to go, the IBEW is more convinced than ever that 

PG&E will be unable to meet the statute’s tight deadlines if exclusivity is maintained. 

While not perfect, the Noteholder plan proposal, now joined by the Official Committee of 

Tort Claimants (“TCC”), provides an alternative, potentially-confirmable path to a timely exit from 

bankruptcy for PG&E, its fire victims, employees, creditors, and other stakeholders. As amended, 

the Noteholder and TCC plan proposal also incorporates the fundamental attributes of PG&E’s 

settlement with the subrogation claim group. See Dkt. No. 4006. In short, the Noteholder and TCC 

plan proposal presents a strong chance for achieving a confirmed plan and a quick resolution of these 

Bankruptcy Cases within the timeframes contemplated by AB 1054. Moreover, the prospect of 

competing plans and the progress already made toward resolving the fire victims’ claims further 

incentivizes all the parties involved in these cases to negotiate a potential consensual resolution of 

their many disputes. 

By contrast, preserving PG&E’s exclusivity and freezing out the Noteholders’ potential 

investment in a reorganized PG&E further aggravates the uncertainty in these cases. PG&E’s 

proposed plan process depends on uncertain estimation outcomes to be determined in at least three 

different forums. Those results could lead to estimated claims that vastly exceed PG&E’s available 

equity investment, that require PG&E to rely more heavily on secured and unsecured debt, and that 

2

 CAL. PUB. UTIL. CODE § 3291. 

3

 Id. § 3292(b). 

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impact PG&E’s balance sheet so unfavorably that both the feasibility of PG&E’s plan and a 

favorable assessment of that plan by the CPUC are placed into doubt. In other words, PG&E’s 

proposed process creates a scenario in which June 30, 2020 arrives and PG&E still faces significant 

funding problems with has no obvious means for either resolving the fire-victim claims or exiting 

bankruptcy. 

In conclusion, although the IBEW does not oppose PG&E’s continuing to pursue its plan, the 

IBEW sees significant value in the Noteholder and TCC plan proposal, particularly in its promise of 

a possible consensual resolution of the claims of tort victims without resort to unnecessary and 

wasteful litigation. On the contrary, the IBEW sees no value whatsoever—especially given the time 

constraints described above—in freezing out from the plan process parties presenting viable and 

potentially better options for a healthy exit from bankruptcy. 

For the reasons set forth above and in the Motion, the IBEW joins in the TCC and 

Noteholders’ request for an order terminating the Debtors’ Exclusive Periods in order to permit these 

parties to file and solicit acceptances of a plan of reorganization. 

Dated: October 1, 2019 Respectfully submitted, 

LOCKE LORD LLP 

By: /s/ Bradley C. Knapp

Bradley C. Knapp 

W. Steven Bryant 

Meagan S. Tom 

Attorneys for Creditor 

International Brotherhood of Electrical Workers Local Union 1245 

Case: 19-30088 Doc# 4046 Filed: 10/01/19 Entered: 10/01/19 14:41:28 Page 4 of

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