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Derrick Talerico (SBN 223763)

dtalerico@ztlegal.com 

David B. Zolkin (SBN 155410)

dzolkin@ztlegal.com

ZOLKIN TALERICO LLP

12121 Wilshire Blvd., Suite 1120 

Los Angeles, CA 90025 

Tel: (424) 500-8551

Fax: (424) 500-8951

Attorneys for Western Electricity 

Coordinating Council

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION

-andPACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors.

Bankruptcy Case No. 19-30088 (DM)

Chapter 11

(Lead Case) (Jointly Administered)

DECLARATION OF HEATHER M. LAWS 

IN SUPPORT OF MOTION OF WESTERN 

ELECTRICITY COORDINATING 

COUNCIL TO FILE PROOFS OF CLAIM 

AND ANY AMENDMENTS THERETO 

UNDER SEAL

Affects PG&E Corporation

Affects Pacific Gas and Electric Company

Affects both Debtors

* All papers shall be filed in the Lead 

Case, No. 19-30088 (DM)

[No Hearing Requested]

Case: 19-30088 Doc# 4188 Filed: 10/10/19 Entered: 10/10/19 18:48:01 Page 1 of

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DECLARATION OF HEATHER M. LAWS

I, Heather M. Laws, declare as follows:

1. I am the Director of Enforcement for Western Electricity Coordinating Council

(“WECC”). In my capacity as such, I manage and oversee the fulfillment of WECC’s 

responsibilities as the regional entity with respect to the operations of Pacific Gas and Electric 

Company (the “Debtor”). I make this declaration in support of the Motion of Western Electricity 

Coordinating Council to File Proofs of Claim and any Amendments Thereto Under Seal, which 

has been contemporaneously filed herewith.

2. As a result of my role and tenure with WECC, I am familiar with the underlying 

claims of WECC against the Debtor. Except as otherwise noted, I have personal knowledge of the 

matters set forth herein and, if called as a witness, could testify competently thereto. Except as 

otherwise stated, all facts set forth in this declaration are based on my personal knowledge, my 

review of relevant documents of WECC, as those documents pertain to the Debtor. 

3. WECC is a not-for-profit corporation responsible for mitigating risks to the 

reliability and security of critical portions of the electrical power grid for the geographic area 

known as the Western Interconnection, which is a 1.8 million square mile area that spans from

western Canada to northern Baja California, Mexico. Geographically, WECC is the largest and 

most diverse of the six regional entities that have delegated authority from the North American 

Electric Reliability Corporation (“NERC”) and Federal Energy Regulatory Commission (“FERC”)

to monitor and enforce mandatory reliability standards for the Bulk Electric System and to serve 

as the Regional Entity within United States portion of the Western Interconnection.

4. WECC’s claims against the Debtor pertain to its role serving as the Regional Entity

with jurisdiction over the Debtor’s operations. WECC is authorized by the delegation of its 

authority from NERC and FERC to issue notices of alleged violations to the Debtor and proposed 

penalties resulting from those violations. In some instances, the violations are self-reported by the 

Debtor to WECC, and in other instances WECC has discovered violations through its own 

independent investigation and audit of the Debtor’s operations. Violations identified by WECC 

cannot be made public, because if the violations were made public, then a “bad actor” could

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potentially discover by reviewing WECC’s proof of claim weaknesses in the Debtor’s physical 

security measures protecting critical energy infrastructure, or flaws in the Debtor’s cybersecurity 

procedures. It thus critical both for the protection of the public and to ensure the reliable 

transmission of energy to consumers that WECC’s proof of claim be filed under seal.

5. WECC intends to file claims in the Debtor’s bankruptcy case, which claims include 

highly sensitive Confidential Information, Critical Energy Infrastructure Information, and Cyber 

Security Incident Information, all as defined in the Rules of Procedure (the “RoP”) promulgated

by NERC. Violations WECC alleges to have been committed by the Debtor cannot be publicly 

attributed to the Debtor because such public disclosure could lead to a circumstance in which one 

or more “bad actors” would be able to identify and target weaknesses in the Debtor’s physical 

security measures protecting critical energy infrastructure, or flaws in the Debtor’s cybersecurity 

procedures. 

6. Even the amounts of WECC’s claims against the Debtor could reveal such 

Confidential Information, Critical Energy Infrastructure Information, and Cyber Security Incident 

Information. If the claim amounts submitted by WECC were made public, they could potentially 

be used by a “bad actor” to identify specific violations committed by the Debtor, which would 

thus reveal Confidential Information, Critical Energy Infrastructure Information, and Cyber 

Security Incident Information. Although the violations asserted by WECC against an entity such 

as the Debtor are public information, including the nature of the violations asserted and the 

associated penalty amounts, the actual identity of the entity that committed the violation is not 

made public in order to protect Confidential Information, Critical Energy Infrastructure 

Information, and Cyber Security Incident Information. 

6. As a consequence, it is critical both for the protection of the public and to ensure 

the reliable transmission of energy to consumers that WECC’s proofs of claim against the Debtor, 

and any amendments thereto, be filed under protection of seal.

/ / /

/ / /

/ / /

Case: 19-30088 Doc# 4188 Filed: 10/10/19 Entered: 10/10/19 18:48:01 Page 3 of

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I declare under penalty of perjury that the foregoing is true and correct. Executed on this 

10th day of October 2019, at Salt Lake City, Utah.

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