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Cathy Yanni (SBN 105036) 

JAMS 

Two Embarcadero Center 

Suite 1500 

San Francisco, CA 94111 

Telephone: 415-774-2635 

Facsimile: 415-982-5287 

Email: cathy@cathyyanni.com 

Administrator of the Wildfire Assistance Program 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION 

- and -

PACIFIC GAS AND ELECTRIC 

COMPANY, 

Debtors. 

 Affects PG&E Corporation

 Affects Pacific Gas and Electric Company

 Affects Both Debtors

This Document Relates to All Cases 

Bankruptcy Case 

No. 19-30088 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

QUARTERLY REPORT OF THE 

ADMINISTRATOR OF THE WILDFIRE 

ASSISTANCE PROGRAM 

Related Docket Nos.: 2223 and 2409 

QUARTERLY REPORT OF THE ADMINISTRATOR 

Cathy Yanni, the court-appointed Administrator of the Wildfire Assistance Program hereby 

submits her first Quarterly Report pursuant to this Court’s Supplemental Order (A) Approving 

Appointment of Administrator and Establishing Guidelines for the Wildfire Assistance Program and 

(B) Granting Related Relief, dated June 5, 2019 [Docket No. 2409] (the “Appointment Order”).

This Quarterly Report provides an update on the status of the Administrator’s work from June 5, 

2019 through October 25, 2019 (the “Reporting Period”). 

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A. BACKGROUND.

On October 8, 2017, multiple fires began spreading throughout Northern California. 

Collectively, the Atlas, Adobe, Blue, Cascade, Cherokee, Honey, LaPorte, Lobo, Macaama, 

McCourtney, Nuns, Norrbom, Partrick, Pocket, Point, Pressley, Pythian, Redwood, Sulphur, Tubbs, 

and “37” fires (“2017 Wildfires”) burned over 245,000 acres and destroyed an estimated 8,900 

structures. On November 8, 2018, another wildfire began near Paradise, California (together with 

the 2017 Wildfires, the “2017 and 2018 Wildfires”), burning over 153,300 acres and destroying 

more than 13,900 residences. The Camp Fire in Paradise is the deadliest and most destructive fire 

in California history. 

On May 1, 2019, Pacific Gas & Electric Company (“PG&E”) filed a motion to establish a 

$105 million fund (the “Wildfire Assistance Fund”) to provide relief from the financial stress and 

burden for those who lost their homes due to the 2017 and 2018 Wildfires (“Wildfire Claimants”). 

The Court approved the motion on May 23, 2019, and appointed Cathy Yanni as the Administrator 

of the Wildfire Assistance Program on June 5, 2019. The Program is intended to provide financial 

assistance to Wildfire Claimants who are in the most need. The Appointment Order requires the 

Administrator to “prepare and, within 30 days after the end of a quarterly period (or such longer 

period as may be agreed to by the Administrator and the Committees or as authorized by Court 

order), file quarterly reports with the Court and serve such reports on counsel to the Debtors and the 

Committees. These reports shall include (i) the number of applications submitted to and processed 

by the Wildfire Assistance Program during the preceding quarter, and (ii) an account of the receipts 

and disbursements from the Wildfire Assistance Fund during the preceding quarter.” 

 

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B. ENGAGEMENT OF PROFESIONALS.

The Appointment Order authorizes the Administrator to engage a team of professionals to 

assist in administering the Wildfire Assistance Program. The Administrator has engaged the 

following professionals: 

(1) David Agretelis, Assistant Program Administrator. An experienced settlement 

allocation project manager who has worked with the Program Administrator on 

multiple MDLs and inventory settlements for over fifteen years. 

(2) BrownGreer PLC, a national settlement administration firm that assists clients with 

the legal and administrative aspects of the design, approval, and implementation of 

claims resolution facilities to provide notice processes, damages payments, and other 

benefits for the resolution of mass claims. BrownGreer’s team is comprised of 

lawyers, analysts, project managers, software developers, claims reviewers, and 

communication specialists experienced in resolving mass claims. 

(3) Bank of America Merrill Lynch, the financial institution selected to hold and 

disburse funds from the Qualified Settlement Fund. 

C. ACTIVITIES DURING THE REPORTING PERIOD. 

Pursuant to the Appointment Order, the Administrator has specific duties to ensure the fair 

and equitable distribution of the Wildfire Assistance Fund consistent with the principles and 

guidelines as established by the Court. These duties include, among other things: (i) determining 

the Eligibility Criteria for participation in and receipt of funds from the Wildfire Assistance Program 

and (ii) consulting with the Federal Emergency Management Agency (“FEMA”) as to the Eligibility 

criteria and prevention of duplicate payments.

1. Establish Eligibility Criteria. 

Following her June 6 court-appointment, the Administrator coordinated with BrownGreer 

to establish the requirements for participation in and receipt of funds from the Wildfire Assistance 

Program (“Eligibility Criteria”), including the types of expenses for which Wildfire Claimants can 

obtain financial assistance and the amount of assistance to be provided to each eligible Wildfire 

Claimant. The Eligibility Criteria ensure that the Wildfire Assistance Fund is distributed in a fair 

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and equitable manner; that assistance is prioritized to those eligible Wildfire Claimants who are 

most in need; and that only eligible Wildfire Claimants receive distributions from the Wildfire 

Assistance Fund. 

As part of this process, the Administrator consulted with the Debtors, Committees, and 

Counsel, sharing the draft Eligibility Criteria for their review and comment. The Administrator also 

extensively coordinated with the FEMA as detailed in section C.2. After incorporating all 

reasonable input and having received no objections from the Debtors, Committees, or FEMA, the 

Administrator filed the Eligibility Criteria with the Court on August 15, 2019 [Docket No. 3556] 

and immediately made a copy available on the public website for the Wildfire Assistance Program. 

2. Coordination with FEMA. 

Pursuant to the Appointment Order, the Administrator consulted with FEMA regarding the 

Eligibility Criteria to ensure eligible claimants do not receive funds from both FEMA and the 

Wildfire Assistance Program for the same expenses. In addition to email exchanges, the 

Administrator had multiple meetings with FEMA, as detailed in Table 1. On August 7, 2019, FEMA 

approved the Eligibility Criteria. The Administrator and FEMA finalized an Information Sharing 

Access Agreement on October 2, 2019. 

Table 1. Meetings with FEMA 

Date Description Contacts Location 

7/1/19 Wildfire Assistance Program 

introduction with FEMA Brock Peterson, Ann Winterman Teleconference 

7/18/19 FEMA discussion on Stafford Act 

and duplicate benefits 

Ann Winterman, Blair 

McDonald, J.P. Henderson Teleconference 

7/25/19 

Meet with FEMA to discuss 

Eligibility Criteria and avoiding 

duplication of benefits 

Ann Winterman, J.P. Henderson Oakland 

8/7/19 FEMA approved Eligibility 

Criteria Ann Winterman, J.P. Henderson Teleconference 

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Table 1. Meetings with FEMA 

Date Description Contacts Location 

10/2/19 FEMA Information Sharing 

Access Agreement finalized 

Ann Winterman, J.P. Henderson, 

Maureen Dimino, Munira Mack Teleconference 

3. Establish Qualified Settlement Fund. 

In June of 2019, following this Court’s entry of the Appointment Order, the Administrator 

and BrownGreer began the process of selecting a financial institution to hold and disburse funds 

from the $105 million Wildfire Assistance Fund. The Administrator and BrownGreer considered 

various factors, including (1) the presence of physical bank branch locations in the geographic area 

close in proximity to the 2017 and 2018 Wildfires (specifically, Chico, CA), (2) the anticipated cost 

associated with the required banking services of each institution, and (3) the anticipated interest 

earnings on the Wildfire Assistance Fund, subject to the Court’s guidelines on how the QSF may 

be invested. The Administrator and BrownGreer explored detailed proposals from three financial 

institutions, ultimately selecting Bank of America Merrill Lynch. 

On July 17, 2019, the Court entered an Order (A) Establishing Qualified Settlement Fund 

for the Wildfire Assistance Program and (B) Authorizing QSF Administrator [Docket No. 3026] 

(the “QSF Order”). The QSF Order established a Qualified Settlement Fund for the Wildfire 

Assistance Program and approved Cathy Yanni as the QSF administrator. 

On July 19, 2019, the Administrator and BrownGreer applied for and successfully obtained 

an Employer Identification Number (“EIN”) for the QSF from the Internal Revenue Service under 

the legal name Wildfire Assistance Program Qualified Settlement Fund. Using that EIN, the 

Administrator and BrownGreer established bank accounts for the QSF with Bank of America 

Merrill Lynch. 

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4. Communication with Potential Claimants. 

(a) Grassroots Outreach Campaign. 

The Administrator led a grassroots outreach effort, visiting the affected communities and 

meeting with community leaders, representatives, and potential claimants to identify trusted 

sources, learn more about the claimant population, and share information about the Program. The 

Administrator designed an infocard and distributed 20,000 copies at community meetings and to 

community groups and agencies for distribution throughout the fire zones. The Administrator 

attended multiple meetings and made presentations, answered questions about the Program, and 

reported on the status of claim filings. Table 2 outlines those community meetings. 

The Administrator personally emailed and personally called unrepresented claimants, 

attorneys, community organizations, and community leaders to promote the Wildfire Assistance 

Program. To increase the informational reach to both represented and unrepresented claimants, the 

Administrator also coordinated with Butte County on a direct mail notice campaign of 15,000 

infocards to residents identified by Butte County as fire survivors. 

In addition, the Administrator consulted with PG&E on their August 15, September 4, and 

October 22, 2019 press releases, which were covered by multiple media outlets, and coordinated 

with Butte County to issue public notice on its website on October 1, 2019. Information regarding 

the Wildfire Assistance Program also is included on community websites, including Butte County’s 

211 site, which provides a direct link to the Wildfire Assistance Program’s website. 

 

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Table 2. Community Outreach 

Date Description Contact(s) Location(s) 

6/7/19 Administrator’s initial site 

visit to Camp Fire Zone N/A Paradise, 

Magalia, Chico 

6/13/19 

Wildfire Assistance 

Program Orientation 

Meeting

TCC, UCC, PG&E, bankruptcy 

counsel and counsel for claimants San Francisco 

7/19/19 

Meet with Butte County, 

Town of Paradise to 

provide information and 

plan collaboration 

Sherri McCracken, Shelby Boston, 

Bruce Alpert, Lauren Gill, Greg Bolin Paradise 

7/19/19 

Meet with Camp Fire 

claimants; tour of Camp 

Fire Zone, Paradise, and 

Magalia 

Karen Gowins (TCC Member) Paradise and 

Magalia 

7/20/19 

Meet with Camp Fire 

claimants and TCC 

Members; tour of Camp 

Fire Zone and Paradise 

Kirk Trostle and Karen Lockhart 

(TCC Members), Patty Garrison 

Paradise, Yuba 

City 

8/14/19 

Coordinate with PG&E 

regarding digital signage 

for satellite offices and 

delivery of 5,000 infocards 

Lynsey Paolo (PG&E Senior 

Communications Manager) 

San Francisco, 

PG&E local 

offices in North 

Bay and Camp 

Fire Zones 

8/20/19 

Meet with State Legislature 

staff regarding Eligibility 

Criteria and claims process 

Staff of Senator Jim Nielson (4th 

District) Chico 

8/20/19 Butte County outreach; 

delivery of 7,000 infocards 

Shelby Boston (Director of 

Employment and Social Services) Oroville 

8/20/19 

Meet with Paradise Town 

Manager regarding 

infocard outreach 

Lauren Gill (Town Manager) Paradise 

8/20/19 

Coordinate infocard 

outreach with Camp Fire 

Zone Captain Organization 

Jenna Murray (Executive Director) Paradise 

8/20/19 

Meet with Mendocino 

County Long Term 

Recovery Group, 

Community Foundation of 

Mendocino County

Rose Bell Teleconference 

8/27/19 

Coordinate with Red Cross 

to discuss Program; 

delivery of 3,000 infocards 

Ann Reynolds (Disaster Director 

Pacific Division) Santa Rosa 

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Table 2. Community Outreach 

Date Description Contact(s) Location(s) 

9/3/19 

Assistant Administrator’s 

presentation at Paradise 

Community Information 

Meeting 

Approximately 200 Paradise 

constituents (with additional 

presentations and attendance by Butte 

County, Town of Paradise, Camp Fire, 

Paradise Unified School District, 

211.org, Paradise Building 

Commission, Paradise Town 

Manager, Butte County Sheriff, 

PG&E, Paradise Ridge Chamber of 

Commerce, Paradise Police 

Department, Cal OES, Paradise 

Recreation and Parks District, and 

Butte County Assessor)

Paradise 

9/6/19 

Assistant Administrator’s 

presentation to Camp Fire 

Long Term Recovery 

Group 

Approximately 100 representatives 

and case managers from FEMA, Legal 

Aid, Butte County Employment and 

Social Services, Faith-based 

organizations, financial institutions, 

volunteer fire services, 211.org, and 

long-term recovery committees 

Chico 

10/10/19 

Coordinate with PG&E; 

delivery of 5,000 additional 

infocards 

Lynsey Paolo (PG&E Senior 

Manager) San Francisco 

10/17/19 

Butte County direct mail 

campaign; delivery of 

15,000 infocards to Butte 

County fire survivors 

Shelby Boston (Director of 

Employment and Social Services) Oroville 

10/18/19 

Administrator’s 

presentation to Camp Fire 

Long Term Recovery 

Group 

Approximately 100 representatives 

and case managers from FEMA, Legal 

Aid, Butte County Employment and 

Social Services, Faith-based 

organizations, financial institutions, 

volunteer fire services, 211.org, and 

Long Term Recovery committees 

Chico 

10/22/19 Administrator’s 

presentation to HopeNow 

Eric Selk (Executive Director of 

HopeNow) and 34 representatives 

from the mortgage housing industry 

Teleconference 

10/23/19 Infocards to Magalia 

Community Church Karen Gowins (TCC Member) Magalia 

 

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(b) Public Website and Social Media. 

Before the Wildfire Assistance Program opened, the Administrator launched an 

informational mobile-friendly public website, www.NorCalWildfireAssistanceProgram.com. 

BrownGreer developed the site, including a customized logo and design. When the website opened 

on July 15, 2019, it included Frequently Asked Questions (“FAQs”), copies of relevant Court 

Orders, a dedicated email address, a toll-free phone number, and an option to sign up to receive 

future Program notifications. 

On August 15, 2019, the Administrator filed the Eligibility Criteria, posted the Criteria on 

the public website, emailed everyone who signed up to receive future notifications, and 

simultaneously opened a secure Portal allowing online claims submission using a computer, tablet, 

smartphone, or similar device. Website updates that day included new FAQs and instructions for 

submitting claims. There have been over 100,000 unique visits to the website to date, 63% of which 

come from users on mobile devices. 

In addition to the public website, the Administrator created a Facebook page on August 5, 

2019, to share program information with the public and amplify community outreach efforts. Over 

8,500 visits to the website have originated from links posted on social media sites (i.e., Facebook, 

Instagram, Twitter, LinkedIn), including direct clicks from the Program’s Facebook page and from 

social media pages operated by local community members, agencies, and organizations. 

(c) Dedicated Call Center and Email Inbox. 

BrownGreer established a Call Center with a toll-free phone number and dedicated email 

address for claimants and attorneys to contact the Wildfire Assistance Program with questions and 

to receive claim filing assistance. Beginning July 19, 2019, the toll-free number provided an 

informational recording including Program information and directing callers to the public website 

to sign up for additional information. Communications Specialists began fielding calls to the tollCase: 19-30088 Doc# 4487 Filed: 10/28/19 Entered: 10/28/19 08:55:18 Page 9 of

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free number on August 15, 2019, after the Administrator filed the Eligibility Criteria. The Call 

Center is staffed with 26 trained, live agents Monday through Friday, 8:00 a.m. to 8:00 p.m. PT and 

Saturday and Sunday, 9:00 a.m. to 5:00 p.m. PT. The Call Center has handled over 11,000 calls 

since opening. 

BrownGreer also maintains a dedicated email inbox allowing claimants, lawyers, and others 

to email the Wildfire Assistance Program. BrownGreer monitors the inbox seven days a week, 

providing quick responses to claimants’ questions and following up with calls to discuss any 

particularly complex issues. When necessary, inquiries sent to the inbox are answered directly by 

the Administrator. 

Claimants and lawyers also have emailed and called the Administrator and BrownGreer staff 

directly requesting assistance and have received responses in less than 24 hours. 

5. Claims Submission. 

Claimants use a secure online portal to complete a single Claim Form for both Basic Unmet 

Needs and Supplemental Unmet Needs claims. BrownGreer worked with the Administrator to 

design and develop this simple, claims filing process that solicits all necessary information to 

determine claimant eligibility for compensation from the Wildfire Assistance Program. The claim 

filing Portal is mobile-friendly, and claimants have accessed the mobile version over 74,000 times 

to obtain Program information, submit a claim, and/or receive claim status updates. 

6. Claims Review and Processing. 

The Program began receiving claims on August 15, 2019, the same day the Administrator 

filed the Eligibility Criteria. The Administrator began reviewing claims immediately and paid the 

first eligible claim on August 28, 2019, thirteen days after the Program opened. 

With support from BrownGreer’s trained claims review team, the Administrator reviews all 

claimant submissions and confirms that the claimed address is located within the boundary of a 

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2017 or 2018 Wildfire, by reference to available data that provides independent information on 

property and fire location. Claimants who do not provide adequate documentation for the 

Administrator to evaluate their claims receive notices outlining the missing information or 

documents and providing the opportunity to cure the deficiencies. Claimants who provide an 

address that is outside the boundary of a 2017 or 2018 Wildfire are notified that they are ineligible 

to receive compensation from the Wildfire Assistance Program. Claimants may submit additional 

documentation for the Administrator to review if they believe the determination is incorrect. 

7. Fraud Prevention. 

The Wildfire Assistance Program implemented a multi-layered approach to fraud prevention 

and analysis. At the front-end, the Program uses a captcha system on its website to distinguish 

human from machine input and uses additional web and data analytics to pinpoint any anomalies in 

website use or claims submissions. The Call Center uses an identity verification procedure to 

confirm each caller’s identity before discussing any claim information, including claim status. 

Additionally, the claims review team is trained to look for irregularities in claim submissions, 

altered documents, and other deviations requiring escalation for review by the Administrator. 

Finally, before confirming a claimant is eligible for payment, the Program completes an independent 

inquiry using third-party sources provided by Lexis/Nexis to verify the claimant’s identity. Only 

after positive verification does the Administrator confirm a claimant’s eligibility for payment. 

8. Payment of Eligible Claims. 

In designing the claims process the Administrator and BrownGreer considered which 

potential methods of payment to eligible claimants would be most effective. In addition to payment 

by check, the Administrator sought to offer methods of payment for those claimants without a 

reliable physical mailing address, as well as those claimants without a bank account. After 

exploring various options the Administrator and BrownGreer determined to offer payment by (1) 

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digital distribution through Zelle®, (2) Prepaid debit card, and (3) check. Zelle is a payment 

application that allows funds to be issued electronically directly to the claimant’s bank account 

without requiring the claimant to provide bank account information. Instead, the application uses 

either the claimant’s mobile phone number or email address associated with his or her Zelle account 

as the secure token to initiate payment. Zelle payments are ideal for claimants who do not have a 

consistent physical address, because they do not require the payment to be mailed. Prepaid debit 

cards are an attractive option for claimants who do not have bank accounts, as claimants can use 

them to withdraw cash at an automated teller machine or at a point-of-sale anywhere that accepts 

Visa. The breakdown of payment methods selected by claimants who submitted a claim form to 

date is: (a) 57% Check, (b) 23% Zelle, and (c) 20% Prepaid Card. 

D. CURRENT PROGRAM STATISTICS. 

As of October 25, 2019, the Wildfire Assistance Program has received 13,572 claims and 

determined 6,742 to be eligible for payment. Since issuing its first payment on August 28, 2019, 

the Program has issued claimant payments totaling $21,552,500 within the first 58 days after 

launching. Table 3 shows receipts and disbursements from the Wildfire Assistance Fund. 

Table 3. Fund Receipts and Disbursements 

 Description Amount 

1. Total Receipts $105,329,292.84 

 (a) Settlement Fund $105,000,000.00 

 (b) Interest Earned $329,292.84 

2. Total Disbursements $22,051,308.75 

(a) Payments to Eligible Claimants $21,552,500.00 

(b) Administrative Expenses $498,808.75 

3. Remaining Funds to Disburse $83,277,984.09 

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Of the 13,572 claims submitted to the Program, 8,303 claimants report that they are 

represented by a lawyer (61%) and 5,269 do not report being represented by any lawyer (39%). 

E. FUTURE EFFORTS. 

The Wildfire Assistance Program will continue accepting claims for Basic Unmet Needs 

and Supplemental Unmet Needs through November 15, 2019. The review of Basic Unmet Needs 

claims is ongoing and will continue until all filed claims have been evaluated to a final 

determination. The Administrator will continue issuing payments on a weekly basis until all eligible 

claims have been paid. 

In addition to processing these Basic Unmet Needs claims, the Administrator will begin 

evaluating Supplemental Unmet Needs claims during the fourth quarter of 2019 with the anticipated 

completion of allocation and payment of all Supplemental Unmet Needs claims within the first 

quarter of 2020. 

F. CONCLUSION. 

The Administrator will continue to perform her responsibilities and duties consistent with 

the Appointment Order and all other directives of this Court and will issue her next quarterly report 

in accordance with the Appointment Order. 

Dated: October 28, 2019 Respectfully submitted, 

 /s/ Cathy Yanni

CATHY YANNI 

Administrator, Wildfire Assistance Program 

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