Attachment to Proof of Claim of United States of America 

In re Pacific Gas and Electric Company Chapter 1 t Case No . .19-30088 (DM) 

A. The Stam.ird Act Provides FEMA a Statutory Cause of Action for Recovering 

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

Cause a Condition Resulting in a Ma_jor Disaster. 

On October 8-10. 2017. over a duzen wi Id fires that became known as lhc "2017 Northern 

California Wildfires'· started in Butte. Lake, Mendocino, Napa. Nevada. Solano. Sonmna. and 

Yuba Counties. California. Cin October 9. 2017, the Governor of California requested a federal 

major disaster dedaralion under section 40 I of the Robe11 T. Slaffr,rd Disaster Assistam:e and 

Emergency Relief Act ("·Stafford Act"), 4:2 U.S.C. §§ 5 I 21 er seq, asserting to the President that 

the State of California \\/as ovenvhelmcd and in need or supplementary federal assistance for 

debris removal, emergency protective measures. repair and replacement of public infrastructure. 

and assistance to individuals impacted by the fires. The President on October I 0. 2017 

deteiwined the 20 l 7 Northern Califclrrtia WildJires were beyond state and local capability and 

issued a major disaster declaration. (FE:\IL!\-4344-DR-CA), auth,,rizing FEMA to provide Public 

Assistance for Butte. Lake. Mendocino. Napa. Nevada. Sonoma. and Yuba Counties. On 

October 12, 2017. the major disash:r dee la ration ,vas amended to authorize Individual Assistance 

t()r Sonoma Coumy. Frorn October I 3-15, 2017. the m~jor dis.aster t.kclanilion \Vas amended 

three more times to authorile Public Assistance for S(,lano County and Individual Assistance fr,r 

Butte, Lake, Mendocino, Napa, Nevada. and '{uba Counties. On November 28, 2017. the major 

disaster declaration was further amended to authorize additional categorit:s of Public Assistance 

for Butte, Lake, Mendocino. Napa. Sonuma, and Yuba Counties. 

Al I wi !dfires that occurred in the declared counties during the incident period of October 8-

3l.2017 arc included in the major disaster declaration FEMA-4344-DR-CA. These wildfires 

include. but are not limited tu: 37 rirc; i\dobe Fire: Atlas Fire: Cascade Fire; Cherokee Fire: 

Honey Fire: La Porte Fire; Lobo fire: McCour1ney Fire; Norrbom fire: Nuns Fire: Pmtrick Fire: 

Pocket Fire; Potter Valley fire: Pythian Hrc: Redwood Fire: Sulphur Fire: and Tubbs Fire 

(referred lo rn!kctively as the ··2017 Northern California Wildfires''). 

The destruction caUs'.:'d by the 2017 Nurthem California \Vildfires \Vas unprecedented at the 

time. h affected tcn5, of thousand~, of people, a11d left millions oftnns of debris in its \'vake. 

According to the California Departmem of Forestry and Fire Protection (Cal FIRE), the 2017 

Northern California Wildfires destroyed 8.585 structures, burned a total of I 75,337 acres, and 

resulted in 42 civilian fatalities and several firefighter injuries. Ca! FIRE Ncv,,rs Release. CAL 

FIRE lnvestiga/m·s De.r.:rmine Causes <f12 Wilc{l7rcs in Mendocino. flwnboldt. Bulle, Sonoma. 

Lake, nm/ Napa Counties (June' 8, 2018). FEMA has incurred significant costs !O provide 

assistance to individuals, s!atc and local governments and private non-profits for their expenses 

and losses re~ulting from the 2017 Northern California Wildfires. To individuals FErv1A has 

provided financial grnn,s f;x housing repair,, rental and other unmet, disaster-caused needs, and 

manufadured housing units for temporary housing. To lhe state and local governments FEMA 

has prc,vidcd di reel federal assistance v,·hich includes goods and services for debris removal 

activities and c:mergency medical response and financial grants for debris remuval, firefighting 

and the repair and replacement of publk infrastrw::ture damaged by the fire. To certain nonprofits FEMA has pmvickd financial g-rants for the repair and replac·ement of facilities damaged 

Case: 19-30088 Doc# 4943-6 Filed: 12/02/19 Entered: 12/02/19 16:07:12 Page 1

of 11
Attachment to Proof of CJairn of United Stat-es of America 

In re Pacific Gas and Electric Company Chapter 1 t Case No. 19-30088 (HM) 

by the fire. In addition, FEi\ilA incurred significant expenses in coordinating. distributing, and 

overseeing this assistance. 

The Stafford Act is clear that assistance under lhe Act is supplemenlary. 42 U.S.C. § 

5122(2). Th~ Act expects FEM.A to offset taxpayer costs from third parties re:~ponsible fiJr the 

event that resulted in 1he need frx a major disaster declaration. 42 U.S.C. § 5 l 60(a). The Act 

mandates FEi\1A avoid duplicating resources available to app.licants frnm insurance and other 

sources. 42 U.S.C. § 5155(a). 

Cai FIRE investigators determined that electrical transmission lines owned and operated by 

Pacific Gas and Electric Company (the Debtor) caused the 37 Fire. Adobe Fire, Atlas Fire. 

Cherokee Fire, Norrbom Fire, Nuns Fire, Partrick Fire. Pocket Fire, Potter Valley Fire. Pythian 

Fire. Sulphur Fire, and Redwood Fire. Cal FJRE Ne,vs Release. CAL FIRE b1vestigators 

Determine Causes of .I 2 Wi/qfires in Afendocino, Humboldt, Bulfe, Sonoma. Lake, and J'lapa 

Counties (June 8, 2018). Cal FIRE fr:irvvarded their investigative report to the County District 

Attorneys Jbr potential prosecution !{ff eight oftbese fires. Id. Cal FIRE investigators also 

determined that electrical tran-;mission lines owned and operated by the Debtor caused the 

Honey Fire, I ,a Porte Fire, Lobo Fire. and MCCourtney fire. Cal FIRE Ne\VS Release, C'AL 

FIRE ftTVestigators Determine Cause of Pour fVih{tlres in Bulle and Nevada Counties (May 25, 

20 l 8). Cal FIRE frmvarded their investigative report to the County District Attorneys for 

potential proserntion 11.-ir three of these fires. Id. Cal FIRE investigators also determim:d that 

electrical transmission lines owned and operated by the Debtor caused the Cascade Fire. Cal 

FJRE Ne,vs Release. CAL FJRE fnve.i;f(gaiors Determine Cause of the Cuscudc Fire (October 8, 

2018). 

According to the pro,~edures set fm1h by the Bankruptcy Court in this proceeding. Debtors' 

liability fr,r the Tubbs Fire will be determined in San Francisc<i Superior Court. If Debh)rs arc 

found to bear responsibility for the Tubbs Fin:" they are liable to the United States for the claims 

assemxl in this proof of claim. 

The 2017 Northern Calil'fm1ia \Vildfires represent s1;;:veral major fires that Cal FIRE has 

attributed to the Debtor· s equipment in the last four years. In addition to the 2017 Nrnihem 

California Wildfires" Cal flRE also determined the Debtor'.s equipment caused the Camp Fire 

that occnrred in November 2018, the deadliest and most destructive wildfire in the history or 

California. Cal FIRF News Rclea:'.e. CAL F:TRE Investigators Determine C'ause of the Camp 

Fire (May 15, 2019). Tbe 2018 Camp F.ire attrihuted to PG&E hurned 153.336 acres. destroyed 

more than 18.000 strucrnres. and caused 85 famiities. The Debtor also caused the Butte Fire in 

Calaveras County in 2015 which bumcd 70,868 acres. 965 stn1ctmes, and resulted in deaths and 

injuries. Cal FIRE News Release. ('AL FTRE hwestigaiors Dettrminc cause ufdesrructive Bulle 

Fire (l\pril 28, 2016). Though caused by PG&E. these fires were included in separate major 

disaster declarations under the Stafford AcL 

Section 317 of the Staffrird Act stales, ''f a]ny p0rson who imcnlionally causes a condition fr1r 

which Federal assistance is provided under this Act or under any other Federal la\v as a result of 

a declara1ion of a major disaster or emergency under this Al't shall be liable to the United States 

for the reasonable costs incurred by lhe United States in responding to such disas1.er or 

3 

Case: 19-30088 Doc# 4943-6 Filed: 12/02/19 Entered: 12/02/19 16:07:12 Page 2

of 11
Attachment to Proof of Claim uf United States of Aml'rica 

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

emergency lo the extent that sw.:h costs are attributable to the intentional act or mnission of such 

person which caused sucb Such action ti:,r reasonable costs shall be m an 

appropriate United Staks district court.'' (emphasis added) 42 U .S.C. § 5 l 6fJ(a). 

FEMA i~ required to seek rcimbur.a,ernent the assistance it provided under the Stafford 

Act. FEIVIA asserts that the cosb it cxpt·nded in disaster assi,tance the 1017 Notthcrn 

Califrimia Wildfires. as described in Item 11, are reasonable and \Vere required by a condition 

caused by the Debtor. PG&E is thcrefc,re liable to the United States for th,::se co:,;ts. 

B. FE.MA Can Recover Disaster Assistance from the Oebtor Because the Debtor 

Created a Public Nuisance. 

The Debtor's creation nf the 2017 Northern Califi:m1ia \t'ildtircs consiitutt-d a nuisance that 

was hannful to health and intcrkred with the comfortable en_.1oyment of life or property. Under 

Calilhmia law. a nuisance is defined as "[a]nything which is injurious to health .... or is indecent 

or offensive to the senses, or an obstruction to the free use of property. so as to interfere with the 

comfortable enjoyment life or property.'· CaL Ch. Code ~i3479. A public nuisance also 

"·affect[ sl at the sanie time an entire conummily or neighborhood, or any considerable numba of 

persons. although the extent of the annnyance or damage inflicted upon individuals may be 

unequal..'" Civ. (\:,de §3480. 

The Debtor created the 20 l 7 Northern California Wildfirn;;s condition causing widespread. 

substantial hann to both peopk and property that is not outw!ighed by the social utility of 

Debwr's condueL With the Staie of Calif.Jmia·s resources rmv1A. expended costs 

to abate the nuisance !hat was the direct res uh of Debtor"s cnnduct and lack of oversighl of its 

electric system. 

C. FEMA 's ProYision of Disaster Assistance U njustl;:' Enriched the Uebtor. i 

Restitution fr.ran unjust enrichment is an appropriate for the Debtor's conduct in 

causing the 2017 Northern California \Vildfires. Restitution·· appropriate be-cause it would be 

inequitable for the Dehtor to retain benefit of FHv'l/\ ·s a:c::istance without paying ns 

value. Tht Debtor received an unjust enrichment from the Federal government because the 

Debtor has nol accepted the fimmcial burden resulti11g from conduct and instead. has relied on 

the public the 10 make the v ktim'> the Provid'ing restitution in the amounts 

described in Item l I \vould renmve some the financial gali1s of the Debtor's conduct and 

would n,quin.· !he Dchtor to pay its friir shan: of recovery. 

ITEtvl l I -- Amount of Claim: 

J: 

The slated arnount of this claim ref1eds the Debtnr"s curr~ntly knm•n1 liability to the 

Depa1t1r1ent of Homeland Security, federal Emergency Man~gemcnt (JF]\ili\J for the : 

Ji 

4 

Case: 19-30088 Doc# 4943-6 Filed: 12/02/19 Entered: 12/02/19 16:07:12 Page 3

of 11
Attachment to Proof of Claim ofllnited States of America 

Io re Pacific Gm~ and Electric CnmJmny Cha1,ter n Case No. 19-30088 ((JM) 

debt described herein, and FFMA reserves the right to arneod, supplement. and/or correct this 

proof of claim. 

This claim is entitled tr) treatment .ls a secured claim under l I U.S.C. § 506 to the extent it is 

subject to setoff by a claim of the Debtor against FEM/\ or uny other United States ag.:.:ncy, 

depmtmeni or instrumentality. The United States is a unitary creditor for purposes of sctofT. 

Any monies identified as mving lO the Debtor by any United States agency. department or 

instrumentality other than FEMA are subject to sctoff against this claim. The administrative 

freeze ot any such monies owing to the Debtor by the United States is \'llithout prejudice to the 

United States· right umJer I I U.S.C. ~ 553 to setpff such monies against lhjs claim. 

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

1. Public Assistance - Direct assistance and financial assistance to the State, local 

gnvl·rnment, tribal gm1:rnmi:nls. and certain private non-profits fbr debris removal, 

emergency protective n1easmes, and the permanent repair/replacement 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) Direct 

temporary housing assistance to individuals and household:, (e.g .. Mobile homes and 

travel trailers); and (.1) Finan-::ial assistance to government agencies or non-profits to 

provide community services for disaster unemployment. crisis counseling. case 

management. and legal services_ 

3. f\1'.1J1}Jni~t@!b~£J:osts -- FEMA 's direct costs incurred in administering: ils m:..tior disaster 

assis1ancc programs. These costs include. but are not limited to, wages, travel. support 

from other F edernl agencies, support from contractors, temporary facility expenses, and 

supplies and equiprnem. 

The below sections provide additional detail on each of these categories of costs. FEMA is 

providing summary spreadsheets accounting for these cc1Sts. The primary spreadsheet FEMA 

utilizes to track disaster specific obligations is the Financial Information Tool (FIT) Report. 

FE1VIA has thousands of pages of documentation available to support each entry on the F1T 

Report ,vhich can bi; made available upon request. 

FEMA 2017 NORTHERN CALIFORNIA FIRES (DR-4344) COSTS 

PUBLlC ASSIST ANCF. 

Fhwncial Assistance 

County Prot~9-~. Worksheets 

Statc~\gcncy Project Worksheets 

Direct Federal Assiswnce 

MissionAssignmcnls 

5 

$ s1,63s, 113_42 I 

$ 279.91 J ,020.7(il 

,,_,,, ~-=1 

$ 7'78 877 - 1 6'' -~ ' ' "-,) -)__~_?_! 

Case: 19-30088 Doc# 4943-6 Filed: 12/02/19 Entered: 12/02/19 16:07:12 Page 4

of 11
Attachment to Proof of Claim of lJ nited States of America 

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

FEMl\ Commodities I s 5. 780. 196.48 

>--------·-·----~·~-<~------------------~------------1 

PA TOTAL I $ l,122,198,926.85 

INDTVlDlJAL ASSlSTA,.~CE >-------------------------------~-------------! 

individuals and Households Program I ·----------I 

, YJousing j\_s_·s_is_·t_an_c_-'.C_----------------------+ __ $ ____ J _J ,'-0_2_5_,2_1 ___ 5_.4_(~) 

Other Needs Assistance (75~;, federal Share) $ 5,203,412.20 

Transitional Shelterirw Assistance $ 3.436.892.33 ,___ _______ ,- "-'~-----------------------------'---------'-------

----------------------------------------1 

I,__ _D_il_·e_c_t _T._e_m~1p_o_r,_:11~J_· l_-li_o_u,_,;i_n=g_A_s_s_fa_·u_11_n_·e __________ LJ; _____ l 6_. ,_7_9_5 . __ 6_8_7_.6_8-1 

I 

~ ____ Disaster Unemployment Assista_n ___ c_e_-_____ ·----------+-----

~ Crisis Counseling Program ___ -------------------1------

Disa~ler Case Management 

$ LI 32513.00 

$ 6.842, l 97. 70 

$ 3.323.1)77.00 --= 

Disaster Legal Servlces $ 5,000.00 

----------------------------~-------

IA TOTAL $ 47,763,995.31 ----------------------~---'----~"---'___c_:...:..__::c:.:::..=---i 

ADMINISTRATIVE, COSTS -------------------------------------------1 

Salaries and Benefits $ 22.320.012.85 ~~-,----------------------------+- -· Travel $ ] 5,374,089.50 

Transportation~ __ ___________ -------------·---------------+------- ,_ $ 424,986.52 

Rem. Communicatirn1',, and lHilmes ----~ - -------~-~---------------------''-- $ 3,723,357.86 

f't:dernl Operations Support ----------------------------+--------C.- $ 6,844,946.60 

Supplics and Materials $ 331,751.33 

$ 22,645.1 l 

$ 2,205A ! 9.22 ~~=~~~-~~·~~=-

$ 6.377.342.66 

_____ _J $ 57.,624,551.65 

2017 NOR CAL FIRES TOT AL 

Puhlk Assistance Costs 

Public Assistance dinxt assistance and financial assislance to the State, local 

government, tribal governrm:nts. and certain private non-profits (Applicant) debris removal, 

emergency protective rneasure::-;, and the perrmmcnt repair/replacement or damaged infrastructure 

6 

Case: 19-30088 Doc# 4943-6 Filed: 12/02/19 Entered: 12/02/19 16:07:12 Page 5

of 11
Attachment to Proof of Claim of llnited States of Amcricii 

In re Padfic Gas and Electrii: Company Chapt.::r 11 Case No. 19-30088 (UM) 

authorind under sections 403,406, and 407 of the Stafford Act. FEl'v1A may provide Public 

Assistance through either 17mmdal assistance or direct Federal assistance, 1 

A. Financial Assistance 

FtJvfA divides Public Assistance into two broad c~m.:gori.;;s: c·mcrgency ·work and pennanent 

work. These types of work are hirthcr subdivided into specific categories as follmvs: 

. Eme:1:g_e:_ocy Work Permanent Work ------------------------------ Category A Debris Removal Category C - Roads and Bridges 

Calegory B - Emergency Protec-rive Measures Category D - Water Control Facilities 

Category E - Buildings 

Category F - Utilities 

Category O - Parks, Recreation, Other 

Debris removal. (Category J\ > includes the removal and disposal of debris frorn public: 

property. FEMA may also reimburse State and local governments for debris removal from 

private properly wht'n it is dctem1incd thal the removal of such debris is in the pnblic interest. 

Emergency prntedive measures (Category B) includes actions taken to save lives and alleviate 

immediate threats to public health and safely such as. but not limited to, fae suppression. 

evacuations. sheltering, and emergency medical care. Perrnanent work (Ca1egories C-G) 

includes the permanent repair or replacement of disaster-darn aged focilitie'>, In addilion, FEMA 

provides Public Assistance fonding fbr administrative costs referred to as Category Z, 

FEMA may provide Public Assistance through either financial assistance or direct Federal 

assistarn:e, llndcr financial assistance, FFMA reimburses the Applicant for the Federal share of 

eligibk work performed by the Applicant. The eligible scope of,vork and cost for each project 

fund;;;d hy FbMA is documented in :1 Project Worksheet. Pmjt·ct Worksheets fl.1r DR-4344 were 

recorded in the EmtTgency i\fanagement Viission Integrated Einirnnm1:nt I EMMIE), a ~ystem 

used to n:eord Federal obligations for the Public Assistance program_ Due to the voluminous 

docurnentutinn supporting each Project \Vorkshcel, this AttachmcrH includes a surnmary 

spreadsheet of Project \Vorkshects for DR-4344. Additional supporting documentation is 

available for each Prujecl Worksheet. which nm be made available upon request. 

B. Direct Federal Assistance 

Beside" financial assisLmc~, fTMA may also provide direct Federal as:s.isinncc for 

emergcnc'.y \VOrk Under di reel h:-d~rnl assistance, the Federal government pm\ ides Federal 

prope1iy or servkes ln perfrinn a specific mission requested by the Stare, FEll.tl'-\ may provide 

commodities or equipment directly to the Stale from existing v,,arehouse stores 1Jr directly 

purchase and provide commodities or equipment, These costs are recorckd in the Enterprise 

Coordination & Approvals Processing System (eCAPS) frir each order. Documentation fix cosb 

1 FEt\tA 11'.lle, i, b only including. tr;;.: f \cdcr,il share of Public Assistance ,;::,is!, in this Pn,of of Claim, Other public 

enlitic~. indudillg the Srntt and local gnvermnents, may be filing a Pnwf of( 'bim for the same projects that include 

the Federal and nori-frdernl stmrc, lff'[MA's daim is allowed by the Cmm, tlw Proofs of Claim filed by the,,e 

other entities may be reduced hy the h:d<:rn! slmre. 

7 

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Attachment to Proof of Claim of United States of America 

In re Pacific Gas and Electric Company Chapter 11 Case No. l 9~30088 (DM) 

associated ·with FEM/\ commodities provided to the State are included in the ·'Immediate Needs 

Assistance'' line itt·m ofthe Financial lnfhrmation Tool Report in Exhibit D. Additional 

supporting documentation is available fr,r each order, which can be madr:: available upon request 

FE!vfA may also task and reimburse another Federal agency. under the authority of the 

Stafford Act, to provide direct Federal as:;islance to a State. The scope of work and costs eligible 

for reimbursement to the other Federal agency are documented in a Mission Assignment, which 

is recorded in eCAPS. Due to the voluminous documentation available to supprni each Mission 

Assignment, this /\tiachment includes a summar:,v· spreadsheet of the l'v1ission .Assignment orders 

for DR-4344. Additional supporting documentation is available fi)r each Mission Assignment, 

,vhich can be made available upon request. 

C. Incident Summar-)' 

The major disaster declaration DR-4344 included over a dozen fire.s in Northern California 

and one fire in Southern California (the Canyon 2 Fire in Orange Count}'). All Public Assistance 

costs directly related to the Canyon 2 Fire are excluded frorn this Proof of Claim. 

FEMA funded Projec'.t Worksheets fbr 55 Applicants located \vithin the affected Counties, 

which are all dirs;;:ctly related to th..:'. Northern Califrirnia fires. FEl',1A fonded additional Project 

Worksheets fr,r 22 State .Agency Applicanls. T\vo Stale agem.:y Project Worksheets included 

costs directly related to the Canyon 2 Fire, and thost: identified costs have been removed. 

FEMA issued two direct Federal assistance Mission Assi1:,'Timents to other Federal agencies to 

provides direct assistance to the State and provided FEMA commodities. 

Indh·idual Assistance Costs 

Individual Assistance includes tinanciai assistance to individuals and households for 

repair/rcplaccrnenl 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 

Staffr1rd Act. Individual A.ssistanu.: also includes financial assistance to governnient agencies or 

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

management, and legal services under sections 410, 4 l 5, 416, and 426 of the Stafford Act. The 

Federal share of Individual Assistance, with one exception, is 100%, of eligible costs. The 

Federal share of the Jndividual and Hm.aseho!d Prngram - Other Needs Assistance program is 

75%, of eligible costs with the State paying the other 25%}. 

A. Assistance Directly to Indi-viduals and Households 

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

Households Program. Under the Individuals and Households Program, FEMA may provide 

financial assistance fr)r the repai r/replaccment of damaged housing. ternporary housing (e.g., the 

cost or renting temporary housing or lodging (~xpenses), and other unmet disaster-caused needs 

(reforred lo as the Other Needs Assistance program) such as replacement o.fpersonal property, 

medical/demal expenses, childcare expenses. and funeral expenses. For DR-4344, the maximum 

8 

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Attachment to Proof of Claim of United States of America 

111 re Pacifi.e Gas and Electric Company Chapter 1 I Case No. 19-30088 (DM) 

amount of financial assistance available under the individuals and Households Program was 

$34,000 for each category of assistance. 

Individuals and households are abo eligible for direct temporary lodging assistance under the 

Transitional Sheltering Assistance program. Under the Transitional Sheltering Assistance 

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

applicants must receive authorization from FEM,L\ lo stay in a Transitional Sheltering Assistance 

prot:,•Tam participating hotel. \Vhen there is insufficient temporary housing available in an 

affected community, FEJVIA may also provide individuals and households ,vitb din::ct temporary 

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

FEMA provides temporary housing hy placing temporary housir:; units on disaster survivor's 

land. commercially leased space, or on group sites built by FEVU\. 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 accessibilit.Y features. 

B. Community Sen,ices Programs 

In addition to as.sistance priwided directly to individuals and households. Fl::,\1J\ provides: 

financial as:-:.i:;tam:e to government agt'ncies or non-profits to provide community services to the 

entire disaster afft.::Hed cumimmity for di:.astcr unemployment crisis counseling, case 

management. and legal services. 

For the l)isas!er Unemploymen1. Program, FHv!A provides fir\ancial assistance to the 

California Employn1ent Development Department to provide ass.i~tance to individuals who have 

disaster-caused unemp.loymenL · 

ror the Crisis Counsding Program. F1:i\1iA pro'ilide& financial assistance to ihe California 

!Jepartrn;.:nt rif I !e'1hhcare Services to fund mental health 1:ounseling fr)r disaster survivors. 

funding is provided under r..,q, g.-r~mts: the Immediate Service~, Prognun and the Regular Si:rvke 

Program. 

For the Disaster Case 1\1fanagement Program, FEMA provides financial assistanct· i.o the 

Califi:m1ia Department of Social Services to provide case management services to disaster 

survivor& to address their unmet needs. 

For the Disaster Legal Services program. FElVIA provides financial assistance to the 

American Bar Association, Young Lawyers Division to fund administrative costs associated with 

coordinating disaster pro bono legal services to individuals affected by a disaster. 

C Incid<:·nt Summary 

The major disaster declaration DR-4344 included over a dozen fires in Northern California 

and one fire in Southern California (the Canyon 2 Fire .in Orange County). AJI Individual 

Assistance costs directly rebted to the Canyon 2 Fire are excluded from this Proof or Claim. For 

the community services programs, all costs supported the Northern Ca!ifrJrnia fire:s. 

9 

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Attachment to Prnof of Claim of United States of Americr, 

Jn re Pacific Gas and Electric Company Chapter l l Case No. J 9-30088 (Ul\l) 

FEl\'JA provided 2, 155 Housing Assistance av,rards and 4,116 Other Needs Assistance awards 

to individuals and households \.Viihin a.ht afft."cted Counties, which are all directly related to the 

Northern California fires. 643 individuals and households ,.vithin !he affected Counties received 

T ransitkmal Shel!ering Assistam.:e fbr a total of 19, 9 l 6 room nights. 

Because of the lack or available temporary housing in the affr·cted community, FEMA 

activated its direct housing program frH" DR-4344. FErvil\ provided 252 temporary housing units 

in the affected n,unties. Direct housing was not authorized for tht..: Canyon 2 Fire. Temporary 

housing units v.ere located on private sites, commercial sites, or group sites modified by FEMA. 

Documentation for costs asc~ociated \Vith temporary housing an: included in ··rvfanufaclllred 

Housing" line item of the FIT Report, 

Administrative CosN 

FE!v1A ·s costs frir administering its major disasl.:-r assistance programs include, but are not 

limitt:d lo. salaries and benefits, travd. support frorn other federal agencies, support from 

contrai:.:tors, H:·mporary fi1cility expens1:s, and supplies and equipment. FEivl/\ "s administrative 

costs are folly funded by the Federal governmenL as there is no State cost share. 

A. Salaries & Benefits 

FEi\1A utilizes both pennanent and temporary staff to support its major disaster assistance 

programs. FEMA's permanent staff are hired under the authority ofTitk 5 of the U.S. Code and 

are funded from regularly occurring appropriations. For pennanent employees. FEl'vtA charges 

overtime ,.;.osts to a s.pecifk: mc~jor disaster dedarnlion, and those arc the unly wages included in 

thi.s Proof of Claim for this category of employee. 

FFrviA ·s temporary employees that support rnajor disaster declarations are hired under !he 

authority of the Staffrffd Act and can be either foll-time or part-time. tu II-lime temporary 

employees are re/erred to as Cadre of On-Call Response Employees (CORE). and part-time 

employees are referred 10 as Resenrisrs. FEMA may also employ local hires that support a 

specific disaster declaration. For all categories of temporary t:mployees. both base wages (e.g .. 

40 hours per week) and overtime spent working on activities directly rdated to a specific major 

disaskr declaration are charged to that 1m1jor disaster declaration and are included in this Proof 

of Claim. 

Time and attendance for all categories of FEiv1A employees is rec,)rded in the Web Time and 

/\Hendance (WebTA) system administerd hy the LLS. Dcpai1mcnt of ligriculture National 

Finance Center, Piiyment made to employees arc rt:corded in the Integrated Financial 

1vfanagement lnfbrmation System ( IFMlS). Due to the voluminous documentation available to 

support these cnsts., this /\Hachmenl includes a summary spreadsheer from the FIT Report 

B. Travel 

ID 

Case: 19-30088 Doc# 4943-6 Filed: 12/02/19 Entered: 12/02/19 16:07:12 Page 9

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Attachment to Proof of Claim of United States of America 

In re Pacitit' Gas and Electric Company Chapte1· l l Case No. 19-30088 (DM) 

FEMA incurs travel expenses 10 ensure staff are on-site to support disaster affected 

communities at the Joint fidd Office, Area Field Office. Disaster Recovery Centers. and other 

locations. TI1cse costs include transportation, per diem (lodging and meals). and other necessary 

expenses in accordance with the F~deral Travel Regulations. FE:tvf A utilizes Concur 

Government Edition for all travel arrangements. induding the processing of travel authorizntfons 

and vouchers. Payments mad£· in supprn1 of approved travel vouchers are recorded in IFMIS. 

Due to the volumin,ms docuffH:ntation ilvailabk to support these costs. this Attachment includes 

a summary spreadsheet from the FIT Report 

C. Tram,portl1tion 

In order to carry out its mission, FFl'>v1A must transport commodities and equipment to 

staging areas and disaster affected locations. Transportation also includes package and 

document delivery services (e.g ... FedEx. UPS. DHL etc.). Orders for transportation services are 

recorded in eCAPS. Due to the voluminous documentation available to supprn1 these costs, thi:;; 

Attachment includ0,~ 3 summary spreadsheet from the FJT Report. 

D. Rent, Communications, Utilities; Print and Reprodm.·tion~ Supplies and Materials; 

Equipment; Other Se1·vices 

In order to pro\ idc its disaster assistance directly to disaster affected communitic:s, FEMA 

operales temporary facilities for each major Jisastcr declarations. Typical temporary facilities 

include the Joint f idd Office. Area Field Offices. Disaster Recovery Centers, and other 

locations. Typi..:al costs incurred in operating these facilities include, but are not limited to, rent, 

utilities, security services. :mdjanitorial services. FEMA also incurs costs for necessary 

supplies. equipment and printing and copy services to operate at these facilities and administer 

its programs. Cush associated with each of these expenses are recorded in eCAPS. Due to the 

voluminous documentation aYai!abk to suppoit these costs, tbis Attachment includes a summary 

spreadsheet from th1.' FIT Report. 

E. Mission Assignments - Federal Operations Support 

In order to carry om its mission, FEMA may task and reimburse another Federal agency, 

under th.,; authority of the StaffrJrd Act to providt Federal Operations Support frlr FEMA. This 

rnay include. but is not limited to, technical experts from other Federal agendes. transportation 

for H]vfA assets and personnel on othl:'r Federal agency vehicles, or supplemental personnel to 

ca1Ty out FEMA li.mcrions. The ,cope of work and cost eligible for rcimburst'ment lo the other 

Federal agency is documi;'.'nted in a Mission Assignment. which is r~cordcd in the Enterprise 

Coordination &. Ap1m:ivals Processing Sysk.rn (eCAPS). Due w the volurninous documentation 

available 1<1 support these t:l•sts, thi:c. Atmchmenl includes a summary spreadsheei from the FIT 

Report. 

F. Contractor Services 

In order to carry out ils mission, FEiv1A. may also utilize the services of Federal contractors to 

provide technical and other :serviu:s. lh.: primary contract me:chani,;m that FE1\1A utilizes tbr 

11 

Case: 19-30088 Doc# 4943-6 Filed: 12/02/19 Entered: 12/02/19 16:07:12 Page 10

of 11
Attachment to Proof of Claim of United States of America 

In re Pacific Gas and Elech-ic Company Chapter I l Case No. 19-30088 (DM) 

major disaster declarations art:. the Public Assistance Technical A::isislance Contract (PA-TAC) 

and ihe Individual Assistance Technical Assist.arn::e Contract T (There is also a Hazard 

Mitigation Technical Assist,mce Contract which is not included in this Proof of Claim.} Orders 

for services against these pre-existing contracts are recorded in eCAPS. Due to the 

voluminous documentation available to these costs, this s1\.Uachment includes a summary 

spreadsheet from the FIT Repon:. 

G. Incident Summary 

The major disaster declaration DR-4344 included over a dozen fires in No1thern Calitbmia 

and one fire in Southern California (the Canyon 2 Fire in Orange County). FE1V1A 's 

administrative costs supported acthities for the lires cannot be separated. FEl'vtA is claiming 

98'};, of costs based on tht; relative damage caused by the Northern Cali fires versus the 

Canyon '.~ Fire. FEMA caku!ated this percentage by comparing: the amount of disaster assistance 

provided for the Northern Califrirnia versus ainount or assistance provided frir 

the Canyon 2 Fire. 

Supporting Dol'umcntation Index 

1D~c1nnent Summary J Pages j 

r-f~i,umcial lnf~rmation J:ool (FlT) Report -----~----~ J : ~:~~ I 

I Summarv S readsheet of Prn'ec! \Vorbheets _ _ ___ _ 

_ Sl!f!J!!1~1JL'.ie~;adshcet of Direct Federal Assistance r,.,1_i_~:,j_~j1.~0_gnments I 40 I 

Summary Spreadsheet of Federal Operations Support I1v1ission AssignrncntsL 4 l -44 ___J 

12 

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