UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA (SAN FRANCISCO DIVISION) 

In re: 

PG&E CORPORATION, 

-and. 

----7 

PACIFIC GAS AND ELECTRIC 

COMPANY. 

D-ebtors .. I 

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

{Jointly Administered) 

Proof of Claim (Fire Claim Related) 

El n 

18 

Read the imitructions before filing this claim form. Thi£ form is for tort claimants who have a claim against the Debtors (i.e. PG&E Corporntion 

and Pacific Gas and Electrk Company) that. arosa prior to the Debtors filing for bankruptcy (Le. prior to January 29, 2019:1 and that arose from, 

or relates to, a fire. 

Oo NOT file a fraudulent claim. A pefson '.<.rt10 files a frau,julent claim eoul,:l be fined up to $500,000, imprisoned for up lo 5 years, or bolh. 18 U_S,C. §§ 1 .52, 

157, and 3571. 

Please type or print in lhe spaces below. Do NOT use rod ink or pencil. 

•#ii Identify the Claim 

I 1- :=~~!r~e current De;a:;en, :,~ H,,::2nd·=~-cu-,,;~,1F~:--e-r@-I F-.• ,-n-~,-9-,.,,-,,.-N-M-,~nag.,,mer,l Agency J 

I Name of th""""""' cred,10, frJ;;c, pcerson ,,, sr,;11y to b<c paid !or lnis claim) . 

I r-----~-~-·-·-----

12- Has this claim been ~ No ·I_', I acquirod from 

I someone else? 0 Yes. From whom? -----------------------_-_-_-_-_-_-_::::::-=·-----_-_-_-_-_-_-_-_-i' 13:--~~ yo:;;~-n~t~::a1: ~~l~-------- ;;~;".;-~ec~-;d-:;,;;;;::-·;i-;;;~-~~~~ide the full name of each family member th;;-;.:;~~-re filing on 

011 behalf of your behalf of; 

family? 0 Yes 

A. family is a gro:Jp of two 

or more people related by 

birth, marriage, domestic 

1mrtnership. or adoption 

and together. A.II 

are 

rcs:mc,.np,-,.,, as member;; 

of one family. 

-t Where should notices 

and payments to the 

creditor be sent? 

federnl l'?.ule of 

Whern should notices to tho creditor besent? 

Cit','-__ 'l_~',B_'?-'f_1:r~-,,.::-1_r,1_n ________________ _ 

iXI No 

Where should payments to the creditor be sent? 

/il dlffemn!) 

(.Jt'>j ________ _ 

S7aU,· ___________________ _ 

Em.t11A,:!dr'6SS_. ·-·-===~---~-----------

5. Does this claim amend 

one already filed? 0 Ye£. Claim nurriber on 1;ourt claims registry {,i!kno,vn) __ _ Flied on 

6. Do you know if anyone 

else has flied a proof 

of claim for this claim? 

iXI No 

0 Yes. \/Vho made the c,J,riier filing? 

MM 1 [rD L;/i_;...Y''-.. ---! 

l 

I 

i 

---------,~~--------------------------------------~~~~--=-»------· _J 

Proof of Claim (Fire Related) 

Claim Number: 59783 1111' UI 1111111 

i93008850010119 

Page 1 

-

Case: 19-30088 Doc# 4943-7 Filed: 12/02/19 Entered: 12/02/19 16:07:12 Page 1

of 12
-

Give Information About the Claim as of the Date this Claim Fo¥m is Filed 

7, What fire is the basis of 

I your claim? 

Cl1ed1 all lhal apply, 

0 Camp Fire 12018) 

D North Bey Fire,; (2017) 

0 Ghost Ship Fino {2016) 

fZl Butte Fire (2015) 

0 other (p!Mise pmvlde dale and briei d,~se;;ipliun of fire _____________________ _ 

What am the loss 

location{s) where you 

and/or your family 

suffered harm? (e.g, 

home or business 

address, place of injury, 

place from which you 

were evacuated, If 

different? 

9, How were you and/or 

your fam!ly harmed? 

Check all that apply 

Location(r): __ f_:e_e_,,_J_ia_c_,1_rn_e_n_t ______________ _ 

0 Property Damage {homes. slrnclures, personal property, land, 1rees, larnfacaping, and all other pmperty 

damage) 

0 Owner O Renier O Occupant O Other (Please specify): 

0 Personal Injury 

0 Wrongful Dea1tl (if checked, ,plea~ provide the name of 1!1e decess«di 

0 

0 

0 

0 

Business losslln1erruption 

Los! wages arn::I earning capac.,ty 

Loss of romrmmit11 and ef.sential &ef'¥ioe5 

Agricultural loss 

ag See attai:nrm,m 

----·---------------.:_';;:::__:0::lll,::e::.r_::(P:_:l=e::asi;::_r::,,,P::,:e:::a::::i'.:::_i).:_: --===========-=-=-=,=-=--=--=-==--=·-=---=.,==-=-=============-_j 0 Ecooorr.ie diim<l{!es (incJoolng replacerr.ent cosl of damaged property, d1minuth:,n In v.;!ua, loss of use. lost 10 What damages are you 

aodlor your family 

claimlng/see!dng? 

invenlrny, losl pro~, and fflM!' er-0nomic dair.age) 

0 Non-economic damages {!liduding lor.s of society and s.upp,-?rt loos of c-0nsortium, piin and suffering, 

emo!Jonal distrei;s, annoyanc.e and disrorofort, and other 11orH!conom1c dama,gel 

CJ Punitwe, exemplary, aoo slatulory damages 

0 Attorney's fees and litigation oost'S 

0 Interest 

0 Any and all other damages recoverable under Callfomla law 

!!I Other {P1.,;ase speetfy) See atlachmenl 

>----------~--~~--,-~~-~~-~ 

I 

11 How m11ch is the claim? 

j O $1 ~tJ ,598.29CL~2 - Sec <fftcichrnenf (()p!iunalj 

l O Unknm~m f To 00 determi~ at a later date 

L~-~--~~~---------------------~~==~~-~--------------------------· 

Proof of Claim (Fire Related) Page 2 

Case: 19-30088 Doc# 4943-7 Filed: 12/02/19 Entered: 12/02/19 16:07:12 Page 2

of 12
•#fl Sign Below 

The person compkting 

this proof of claim mui;1 

sign and date it, 

fRBP 9011(b). 

specify,ng whi!lt .!! ~h3nature 

Is. 

A person who files a 

fraudulent claim could be 

fined up to $500,000, 

imprisoned for up to 5 

years, or both. 

18 u.s.c. §§ 152, 157, and 

3571. 

C/lec~ /he appropriate bo;, 

Cl I ;:;rn the cr.edilrn. 

~ I am !he credl!oc's a!lom,:;y o, authori;:ed agent 

I have m,:amin,'!d lhft lnformati,Jn in !hi::; Proofof Claim and have a reasomiti!,; be!iei that !he iniomialilm is !rue 

and correct 

Prlnt the name of the parson who is completing and signing this clahn: 

Regional Adrnrnislr.3tor ----~~---·-"------

11 i i?,r,J,ii.dwsy, Si.iite ·12G-D 

---------------------·--···--··---"-------------- Str,;;:-et 

CA 

ZiP Code 

-5lD-627-7iLJO 

Proof of Claim (Fire Related) Page 3 

Case: 19-30088 Doc# 4943-7 Filed: 12/02/19 Entered: 12/02/19 16:07:12 Page 3

of 12
Attachment to Proof of Claim of United States of America 

in In re Pacific Gas and Electric Company 

Chapter 11 Case No. 19-30088 (DM) 

pending in the United States Bankruptcy Court for the 

Northern District of California 

Name of Creditor and Addres:,: 

United States of Amcric::, 

Depmtment of Bnmeland Security 

Federal Emergency tvlanagement 

Region lX 

l l I l Broadv,1ay. Suite l 200 

Oakland. 94607 

Attn: Robert J. Fenton 

Name_lJpd Address Where Notices Should Be Sent: 

1vlATTIIEW J. TROY 

Civil Division 

l 1.S. lkpartmt'nt 

P.O. Box 875 

Ben franklin Station 

\Vashington. D.C 20044-0875 

AUrxncy for United S13tes 

Telephone numbers: 

(202) 514-9038 (Matthe-vv l Troy) 

A~cmmt or other number by 1-vhich credjtoridcntiflcs debtor: 

None. 

ITEI\1S 8. 9. and l O ···· Loss l .oca!ion. Harm. and Damages: 

filing this claim !he Proof of Claim (I-i'ire Claim R1dated). the United Stak~ {a) 

does nnt concede that this dairn is a Wildfire Claim. as defined in the fkhlors · .Motion Pursuant 

to 1 l l/S.C 105(a) and Jor Estahlishmcnl of ( E:srimathm 

Pmcedwvs. Docket No. 3091; !b) rt·serves right to argm:· that this claim is not subjecl tn 

estirnation; and (c} n·scrn:s its right to to any plan of reorganization filed in the Debtor·s 

ca.,;e that purports tc, classify the United States· \-vildfire relakd ims as \\iildfirc Clairns 1,vhose 

only source of recovery is a litigati1,n trust with a channeling injunction and a capped funding 

amount established pursuant to an estimalion proceeding. 

Case: 19-30088 Doc# 4943-7 Filed: 12/02/19 Entered: 12/02/19 16:07:12 Page 4

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Attachment to Proof of Claim of United States of America 

Jn re .Pacific Gas and Electric Com1i:u1y Chapter H Case No. 19-30088 (D!vf) 

A. The Stafford Act Provides FEMA a Sfatutory ('..rnse of Action for Recovering 

.Federal Assistance from Persons Who, by Their Intentional Acts or Omissions, 

Cause a Condition Resulting in a Major Disaster. 

On September 9, 2015. a wildfire that became known as the "Butte Fire'' started in Amador 

County, California and quickly spread to Calaveras County, California. On Septembc:r 21. 2015, 

the Governor of Califr)mia requesled a lcdcral major disaster declaration under section 40 I of the 

Robert T. Stafford Disaster Assistance and Emergency Relief Act ('"Stafford /\cf'), 42 U.S.C. §§ 

512 l et seq, asserting to the Pre:-.ident thal the State of California was oyenvhclmed and in need 

of supplemenlary foderal assistance for debris removal, emergency protective measures, repair 

and replacernent of public infrastrncture, and assistance to individuals impacted by the Butte 

Fire. The President on September 23. 2015 determined the Butte Fire 1vvas beyond state and local 

capability and added it to an exi.sting major disRster declaration for a fire burning ccmcum,:mly 

(FEMA-4240-DR-CA ,L authorizing FEMA to provide Individual Assistance for Calaveras 

County. On Seplemb~r 24. 20 l 5 and October 8, 2015. the major disaster declaration was further 

amended to authorize Public Assistance for Calaveras County. 

The destmclion caused by the Butte Flrt affected thousands of people and left hundreds of 

thousands of tons nf d,.::bris in its ,vake. According to th;: California Depaiiment of Forestry and 

Fire Protection (Cal FIRE), the Butte Fire destroyed 965 structures. bumcd a total of70.868 

acres, and resulted in deaths and i11juries. FEMA has incurred significant costs to provide 

assistance lo individuals, stale and lo<:al governments and private non-profits ff1r their expenses 

and losses resulting from the BuHc Fire. To individuals FEMA ha:, provided fimmciaJ grants for 

housing repair. rental and other umm,l, disaster-caused needs, and manufatetured housing units 

for temporary bousing. To the st::1te and local governments FEIVIA has provided direct federal 

assistance vvhieh includes good:, and scrvkcs fr)r dchris removal activities and ;;;mergency 

medical response and financial grants fr,r debris removal, tirdighiing and the repair and 

repl<1cement of public infrastrncture damaged by the fire. To certain non-profits FE!VIA has 

provided financial grants for the repair and n:placcment of facilities damaged by the fire. In 

addition, FEMA incurred significant expenses in coordinating. distributing, and overseeing this 

assistance. 

The Stafti.)rd Act is clear that assistance under the Act is suppieme·ntar), 42 U .S.C. § 

5122(2). The Act expects FFMA to offset taxpayer costs from third parties responsible for the 

event that n:sulted in the need for a rm:uor disaster dcclara1ion. 4:2 U,S.C § 5 l 60(a). The Act 

mandates FEMA avoid duplicating resources available 10 applkarm from insurance and other 

sources. 42 lLS.C. § 5155(a). 

Cal FIRE investigators detennined that electrical transmission lines <•wried and operated by 

Pacific Ga-. and Electric Company \the Debtor) cawsed the Butte Fire. Cal FIRE News Release, 

CAL FIRE Investigators De/ermine Cause o{Desrructive Butte Fire !April 28. 2016). C::il FIRE 

forwarded their investigative report w the County District Attorney for potential prosecution. ld 

In the years le~1ding up to the Butte Fire, the California Public Utilities Commission found 

thal the Debtor had failed!,:; efkctively cure critical safety problems and manage risk 

appropriately. putting PG&E on notice that its distribution system had significant saleiy 

2 

Case: 19-30088 Doc# 4943-7 Filed: 12/02/19 Entered: 12/02/19 16:07:12 Page 5

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Attachment to Prnof of Claim of United States of America 

In re Pacific Gas and Elcctrk Company Chapter 11 Case No. l 9-30088 {DM) 

issues. The Butte Fin: was the first of several m~tjor fires that Cal r:JRE has attributed to the 

Debtor's equiprns:nt in the bs:t fonr years. In addition to Butte Fire. Cal FIRE also determined the 

Debtor·s equipment caused lhe Camp Fire that occurred in November 201 &. the deadliest and 

most destructive ,vildfire in the history of California. Cal FIRE News Re.lease, CAl FIRE 

Investigators fle1ermine Cause u/!he Camp Fire (!'v1ay 15. 20 l 9). The 2018 Camp Fire 

atirihuted to PG&[ humed I 5.LU6 acres. <lcs.troyed more than 18,000 slructures, and caused 85 

fatalities. The Debtor also caused the '..'.OJ 7 Northern Calil'bmia Wildfires in October 2017 which 

destroyed 8.585 structures, burned a lotal of 175.337 acres. an<l resuilcd in 42 civil.ian fatalities 

and several firefighter injurit'.S, Cal I IRE News Release, CAL FIRE Investigators Derer.mine 

Causes 1,fJ2 Wildfires in A:fendocino, Humboldt, Bulle, Sonoma, Lake, and Napa Counties (June 

8, 2018). Though caused by PC&L. thesr: fir.;:s were included in separate major di,;::istcr 

declarations under the Stafford Act 

Section 3 l 7 of the St.dTnrd Act states, .. [a ]ny person who intentionally causes a condition for 

which Federal as~istance is prnviJed under thi 1; Act or under any other Federal !av.' as a result of 

a declaration of a major disaster or emergency under this /\ct shall be liable to the United States 

for the reasonable costs incurr,:,d by the United States in responding tc. such disaster or 

emergency to the extent that such rnsLs are attributable to the intentional act or omission of such 

person which <:auscd such condition, Such action fc.,r reasonable costs shall be brought in an 

apprnpriate !Jnit-::d States district court:· (emphasis added) 42 U.S.C. § 5 l 60(a). 

FEMA is required to seek reirnbursemem for the assistance iJ. provided under the StallcJrd 

Act. FEMl\ nsscrtc. that th,;; costs it expended in disaster assistance for the Butte r ire. as 

described in hem I I. an: rea';onnh!e and were required by a condition mused by the Debtor. 

PG&E is therefore lk1blc to the l fnitt'.d States for th1..·sc costs. 

B. FEMA Can Recover Disaster Assistance from the Debtor Bec~rnsc the Debtor 

Created a Public NuisarH."c. 

The Debtor's creation of the Butte Fire constitukd a nuisance that was harmful to health and 

imerfrrC'cl \,iith the comfortable rnjoyrnent nf life or property. Under C::.-tli fornia la\v. a nuisance 

is Jefinc:d as ··[n]nything ,vhicb is injurious to health, . ., or is indecent or offensive to the senses. 

or an ohslrndion tn the free ust: o/' prnpc,1y, so as to interfere with the comfortable enjoyment of 

life or properly." Cal. Civ. Cnde §3479. A public nuisance also "affect[sl at the same time an 

cntirl2' community or neighborhood, or any considerable number \)f persons, although the extent 

of the annoyance or damage irdlicted upon individuals may be 11nequa1.·· Cal. Civ. Code §3480. 

The Debtor created the Butte Fire condition causing widespread. substantlal harm to both 

people and property !hat is not outweighed by the social utility of Debtor·s conduct. With the 

State ofCalifi;)rnia·., rcf:;ources ovt-rwheilm:d. FEMA expended costs to abate the nuisance that 

was the direct rc~mlt of Debtor·:s 01nduct and lack of oversight of its l'k(:tric system. 

C. FEMA's Provision ofUis.ister Assisurnce Unjustly Enriched tbe Debtor. 

Restitution fix an unjust enrichment is an appropriate remedy for the Dehwr·s conduct in 

cc1using !he Hutk Fire. Restitution is appropriate because it would be inequitable for the Dehtor 

3 

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Attachment to Proof of Claim of Un itcd States of America 

In re Pacific Gas and Electric Company Chapter 11 Case No. 19-30088 (UM) 

to retain the benefit of FEMA ·s assistam:e without paying for its value. The Debtor has received 

an unjust cnr.ichmeni from the Federal government because the Debtor has not accepted the 

finani;:i;1l burden resulting from its condud and instead, has relied on the public fisc to make the 

victims of the fir.e whole. Providing restitution in the ammmts described in Item 11 would 

remove some of the financial gains of Llw; Debtor· s conduct and would rcqulre the Debtor to pay 

i1s fair share of recovery. 

JTEM J l - Amount of Claim: 

Oveniew 

rhe stated amount of this claim reflects the Debtor's crnwntly known liability to the 

Department of llomdand Security, Federal Emergency Management Agency (FEMA) for the 

debt described herein, and FEMA reserves the right to amend, supplement and/or correct this 

proof of claim. 

This claim is entitled tn treatment as a secured claim under l l U.S.C. § 506 to the extent it is 

subject to setoffby a claim of the Debtor against FEMA or any oth.:;r United States agency, 

department or instnm1entality. The United States is a unitary creditor fix purposes of setoff.. 

Any monies identified as ovving to the Debtor by any United States agency. department or 

inslmmcntality other than FEJ\tA are subject to setoff against this claim. The administrative 

freeze of any such monies ()wing to the Debtor by the United States is vvithout prejudice to the 

United Stares: right under l l U.S.C. § 55:i to setoff such monies against this claim. 

Costs associated with FE1VLL\ ·s Proof of Claim has three broad categories: 

i. Public /\ssisJ.::mce - Direct assistance and financial assistance to the State, local 

government tribal governments, and certain private non-profits for debrb removal. 

emergency protective measures. and lhc permanent repair!rcplac.:t'ment of damaged 

infrastructure. 

2. Individual Assistance-· ( l) Financial assistance to individuals and households for 

repair/replacement of damaged housing. temporary housing, and other needs: (2) Direci 

temporary housing assistance to individuals and households (e.g .. Mobile homes and 

travel trailers): and (3) Financial assistance to govemrncnt agencies or non-profits to 

provide community .services fix disrL;;;ter unemployment crisis counseling, case 

management. and legal st-rvices. 

3. Administrative Costs ... FEI\lA ·s dirccl costs incurn:d in administt'ring its major disaster 

assistance programs. These costs include, but are not fonitcd to, wages, traveL support 

from other tederal agencies, suprurt from contractors, temporary facility expenses, and 

supplies and equipment. 

The below sections provide additional dt:tail on each of these categories of costs. FEM/\ is 

providing summary sprel:ldshects accounting for these costs. The primary spreadsheet FEMA 

4 

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Att~lch mcnt to Proof of Claim of United States of America 

In re Pacific Gas and Ekctl"ie Company Chapter 11 Case No. 19-30088 (Dl\l) 

uti to track disaster lk obligation,, is the Financial lnformation Tool (FIT) Report 

FEivlA has thousands ofpc1ges of documentation available to support each on the Fff 

Report which can available upon request 

FEMA Butte Fire (DR-4240) Co!it Smnm~ry 

POBUC ASSISTANCE 

Financial Assistance I 

County Project Worksheets I $ 12,939,516.63 

State Agency Project \Vorks.heets ·----------~ I ____ s l_l_6_.9-~~-_.8_9~~l3 

!---------------------------

Direct Federal Assistrmce 

Mission Assignments 

FEMA Commodilies 

~ I 

$ '• 

$ 

l, I 59,552.47 

.-,8 j .J, ·~o I ,ht'!'~~ 

I ~~-·~=~ 

131,051,0~H.73 i >-------------------------~-----

PA TOTAL $ 

·-

INnIVJDl.!AL ASSISTANCE 

Individuals and Households Pro:;zram r---=-----~~-~-••----~-~--------------j---·------------1 

__ l_h_)t_is_in_,6"'- 5 _A_s_si_s_ta_n_c_c ________________ J_~J, _____ "-1_· ._I _94_' ._5_6_4_.6_8....., 

Other Needs i\ssi5tancc (75'lh Fedtral Share) I $ 781.4 J 2.38 

r Transitional Sheltering Assbtance $ 89J 68.86 

[---- --~---·,----~· ~-·-a~ 

. ( ·mnnumily St.'rviccs Pm.1,,11·oms 

-~---------------+ 

Disaster mployment Assistance 

Crisis Counseling Program 

IA TOTAL 

$ 

$ 

6.28 I .254.02 

454,073.36 

287.921.82 

12,088,395.12 ~----------------------·----~-----------, 

ADMINISTRATIVE COSTS 

Salaries and Benefits $ 8.599.187.13 -----~~--~-----=~=-~-------~-----------~~---f...-----

Travel $ 4219,227.24 

l ransportation $ 70. 189.72 

,nt, Communications. and Utilities $ 8%.4l l.82 

$ L055.768J)2 

$ l l 1 .785.68 

$ l 04,393.50 

$ l ,Ol6JJ84. l 7 

$ 1.385,756.09 

l 0Lht:r Services 

L~(2.f~lE:1.9ts:ir Sen ice~---·-·----·--·-···-- .. -· ... ·----~-···-·--·---_J_ ________ _ 

5 

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AttacJnmmt to Proof of Ck1im of United States of America 

In re Pacific Gas and Electric Company Clrnpter I J Case No. l 9-30088 (UM) 

B ll TTE FIRE TOT AL ! $ 160,598,290.22 

Public Assistance Costs 

Public Assistance includes direct assistance and financial assistance to the State, local 

government, tribal governments, and certain private non-profits (Applicant) for debris removal, 

emergency protective measures, and the permanent repair/replac:,.'ment of damaged infrastructure 

authorized under sections 403,406. and 407 of the Starford Ac:L FEMA may provide Public 

Assistance through either financial assistance or direct federal as:,istancc. 1 

A. Financial ·Assistance 

FEivIA div ides Public Assist<1nce into two broad categories: bm.:Tgcm.:y wm'k: and permanenl 

work. These types of work arc further subdivided into specific c2tegories as follows: 

Em~rgency Work 

Category A. - Debris Removal 

Category B - Emergency Protective Measures 

Permanent Work 

Categorv C - Roads and Bridges 

Categor; D - \llater Control Facilities 

Category E -- tiuildings 

Catego1-y F - Ltilities 

Category G - Parks, Recreation. Other 

Debris removal (Catf:gory A) indudes the removal and disposal of d.:,,bris from public 

property. FEfV!i\ may also reitnburse State and local governments for debris rernoval from 

private property ,vhen it is determined that the removal of such debris is in the public interest. 

Emcr!;!encv p ... rotective measures (Cate2:on1 B.) includes actions taUen to save lives and alleviate ~ "' ' ...., ,.-

immediate threats to public health and safety such as. but not lim'tted w. fire suppression. 

evacuations, sheltering. and emergency medical care. Permanent vvork (Categories C-Ci) 

includes the permanent repair or replacement of disaster-damaged facilities. In addifam, FEMA I 

provides Public Assistance funding for administrative costs refer)'ed to as Category Z. 

FEMA may provide Public Assistance through either fimmci~il assistance or direct Federal 

assistance. Under financial assistance, FEM/\ reimburses 1he Applicant for the Federal share of 

eligible work perfi)m1ed by the Applit:ant The eligible scope of work and cost frir each project 

fonded by FEl\-1A is documented in a Project Worksheet. Project Worksheets for DR-4240 were 

recorded in the Emergency Management [\,fission Integrated Environment (ElVll\UE). a system 

used to record Federal obligations for the Public Assistance program. Due to the voluminous 

1 F EMA noti~,; it is only including the Fe·d0rn! share of Public Assistance co:,ts in this Proof of Claim. Other public 

eniities, in,Juding the St.He and lorn! governments, rm1y he riling a ProofofCiairn for the same projects that include 

the Federal and non-hderal share. !fFEMA.'s dairn j,, alkiwed by !he Court, the Pro;:ifa of Claim filed by these 

other entities may be redu;.;ed by the Federal $hare, 

6 

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Attachment to Proof bf Claim of U nitcd States of America 

In n.· Pftcifk Gas and Electric Com pan,, Chapter H Case No. 19-301188 ( DIV() 

documentation supporting each Project Worksheet, this Attachment includes a surnrnary 

spreadsheet of Project \Vorkshcets fr,r DR-4240. Additional supporting docu,ncntation is 

available tcir each Project \Vorkshcet which can be made available upon request. 

B. Direct Federal Assistance 

Besidt'S financial assistance. FEi'v1A may also provide direcl Federal assistance for 

emergency work. Under dired h:dcral assistance, the Federal government provides Federal 

property or services to perform a specific mission requested by lhe State. FEMA may provide 

commrxlities or et1uipment directly to the State from exisling warehouse stores or directly 

purchase and provide commodities or equipment. These costs are recorded in the Enterprise 

Coordination & Approvals Processing System (eCAPS) fbr each order. Documcnta!ion for costs 

associated with FEMA commoditie~ provided 10 the· State are included in the '··Immediate Needs 

Assistance·· line item of tht: Financial Infom.ation Tool Report in Exhibit D. Additional 

supporting documcmatinn is available for each order, \Vhich can be made available upon n:quest 

FEMA may also task and rdmhurse another Federal agency, under Lhe authority of the 

Staffbrd Act, to pr(1vide direct Federal assisrance to a State. The scope of work and costs eligible 

for reimbursement to the other Federal agency are documented in a Mission Assignmt:nt, vvhich 

is recorded in eCAPS. Due to the voluminous drn:umentation available to suppGrt each J'Vlissinn 

Assigrunent, this Attachment intludes a sumrnary spread shed of the Mission Assignment orders 

for DR-4240. Additional supporting documentation is available for each Mission AssigTlment, 

which can be mack available upon request. 

C. Incident Summary 

The mo~jor disaster declaration DR-4240 included both the Valley fire (Lake County) and 

Butte Fire (Calav~ras CnuntyJ. All Public As-;istancc costs directly related to the Valley Fire are 

excluded fron1 this ProofofUaim. !or Stnk Agency work that supported both the Vailey Fire 

and Bune Fin:·. FETvl/\ is d3in1ing 55'%, of costs based on the relative damage caused by the 

Valley fire versus t!w Buue lire .. FEMA calculated this percentage by comparing State Agency 

costs that were directly related to the Butte Fire versus tJmse directly related t.o th-:- Valley Fire. 

FEivlA fimdtxl 33 Project Worksheets !i,r Applicants locat,:;d with.in Calaveras County, 'Which 

are all directly related io the Butte Fire. FEMA fonded an additional J7 Project 'Worksheets lbr 

State Agency Applicants. Nine {9) of the Srn.te Agency Project Worksheets 'were fix work solely 

performed in Cnlavcras County and art: all directly related to the Butk Fire. Sixteen ( l 6) of the 

State Agt"ncy Project Worksheets v,ccrc for ·work solely perfom1ed in Lake County and are not 

related ll• the Butte Fire. l he remaining 12 of the State Agency Project \:V orkshects were for 

work supporting both the Valley and Butte Fires, so FEMA i::; daiming 55~;; 1)f the costs. 

FE!\IA i5sued IWQ dire,:I Fcdern! a<,sistance Mission Assignments to othi:r Federal agc:m:ics to 

pr,:rvicks dircn assistance to the Srntc These 2 1V1ission As.,ignmentc; :-:.upponed bmh lhc Valley 

and Butte J·ires, SfJ FEMA is claiming 55%, of the costs. FEMA commodities \\/ere also provided 

for both fires. so Flcl\lA i-o claiming 55% of the costs. 

7 

Case: 19-30088 Doc# 4943-7 Filed: 12/02/19 Entered: 12/02/19 16:07:12 Page 10

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Attachment to Proof of Claim of United States of America 

In re Pacific Gas and Electric Company CJ:mpter H Case No. 19-30088 (OM) 

Individual Assistance Costs . 

Individual Assistance includes financial assistance to individuals and households f;:ir 

repair/replacement of damaged housing, temporary housing, and other needs and direct 

temporary housing assistance (e.g., Mobile homes and travel trailers) under section 408 of the 

Stafi<)rd Act. Individual Assistance also includes financial assistance to government agencies or 

non-profits to provide community services for disaster unemployment, crisis counseling, case 

management, and legal services tinder sections 410,415,416, and 426 of the Stafford Act. The 

Federal share of Individual Assistance. v,:ith one exception. is I 00% of eligible costs, The 

Federal share of the Individual and Household Program - Other Needs Assistance program is 

75% of eligible costs ,vith the State paying the other 25%1. 

A. Assistance Directly to Individuals and Households 

Assistance directly to individuals and households is provided through the Individuals and 

Households Program. Under the lndi'viduals and Households Program, FEMA rnay provide 

financial assistance fbr the repair/replacement of damaged housing, temporary housing (cog., the 

cost of renting temporary housing or lodging expenses), and other unmet disaster-caused needs 

(referred to as the Other Needs Assistance program) such as replacement of personal property, 

medical/dental expenses. childcart expenses, and funeral expenses. For DR-4240, the maximum 

amount of financial assistance available under the Individuals and Households Program \Vas 

$32.900 across all categories of assistance. 

Individuals and h,1useholds are also eligible fur direct temporary lodging assistance under the 

Transitional Sheltering Assistance prograirL Under the Transitional Sheltering Assistance 

program, FEM/\ directly pays participating hotels lo house disaster survivors. Eligible 

applicants must receive authorization from FEMA to stay in a Transitional Sheltering Assistance 

program participating hotel. When there is insut1kicnt temporary housing available in an 

amxtcd community, FEMA may also provide individuals and households with direct temporary 

housing assistance through temporary housing units such as a mobile homes and travel trailers. 

FE1\rlA provides temporary housing by placing temporary housing units on disaster survivor's 

land, commercially leased space. or on group sites built by FEMA. Costs associated with a 

direct housing mission include purchase. transportation, installation. and removal of a temporary 

housing unit. lease costs for a temporary housing unit site, and other incidental expenses such as 

utilities or installation of accessibllity features. 

B. Community Services Programs 

In addition to assistance provided directly to individuals and households. FEM;\ provides 

financial assistance to government agencies or non-profits to provide community services to the 

entire disaster affected community for disaster unemployment crisis counseling, case 

management, and legal services, 

8 

Case: 19-30088 Doc# 4943-7 Filed: 12/02/19 Entered: 12/02/19 16:07:12 Page 11

of 12
Attachment to Proof of Claim of United States of America 

ln re Pacific Gas .and Electric Compan:y Chapter 11 Case No. 19-30088 (OM) 

For the DisasH:r Unemployment Program, fl MA provide:-; financial assistance to the 

California Lmployrnent Development Departrnenl to provide assistance l.o individual.:; who have 

disaster-caused unemployments 

For lhe Crisis Counseling Program, FEMA provides financial assistance to the California 

Department of Healthcare Services to fund mental health counseling fix disaster survivors. 

Funding i~; providcd under Lwo b'n1ms: the Immediate Services Program and the Regular Service 

Program. 

C. Incident Summary 

The im~jor disaster dcdarntion DR-4240 im:lud!.';d both the Valley Fire {Lake County) and 

Butte Vire (Calaveras County). All Individual Assistance costs directly related to the Valley Fire 

arc excluded from this Proof of Claim, Fur the community :services programs that supported 

both the Valley Fire an<l Butte Fire. FEM/\ is claiming 41 % of cosls baseJ on the relative 

damage caused by the Valley fire versus the Butte Fire. FEivti:\ calculated this percentage by 

comparing the amount of financial assistance provided to disaster survivors impacted by lhe 

Butk Fire versus those disaster survivors directly impacted by the Valley Fire. 

F EfvlA provided 597 Housing Assistance awards and 312 Other Needs Assistance awards to 

individuals and households within Cala.c·ras County, which are all directly related to the Butte 

Fire. Twenty-eight (28) individuals and households 1.vithin Calaveras County received 

Transitional Sheltering Assistance for a total of 883 room nights. 

Because of the lack of available ternpurary housing in !he affected community, FE.~1A 

activated its direct housing program fi::ir DR-4240. FEMA provided 32 temporary housing units 

in Cakrvems County. which rcpresent;;d 39'Vi, of all temporary housing unib provida;"d for DR4240. All tempc,rary housing unih were located on private sites or commercial sites, 

Docmn~ntalion for costs assoduted vvith temporary housing arc included in the ''Manufr1ctured 

Housing" line item nf the FIT Report. 

Administrative Costs 

FEMA's costs for administering ils major disaster assi"t,mce programs im:lud;;:, but are not 

limited to. 'ialaries and benefits;, travel, support from other Federal agencies. support from 

contractors. temporary facility expenses. and supplies and equipment. FFl\·1A'c, administrative 

costs are fully fonded by the Federal government, ns there is no State cost share, 

A. Salaries & Benefits 

FFi'Vl/\ utilize:, both permanent and ternpornry staff to :-upport its major disaster assistarnx 

programs. FHvlA's permanent staff are hired under the authority of Titk 5 of the 11.S, Code and 

are funded from regularly occurring appropriations. for pennanenr employees. FPvfA charges 

overtime costi; to a specific major disaskr declaration, and those ar? the only wages induded in 

this Prnnf of Claim for this category of employee, 

(J 

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