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3190775 -1- 

DECLARATION OF BRAD PROCTOR

Sblend A. Sblendorio (SBN 109903) 

HOGE, FENTON, JONES & APPEL, INC. 

4309 Hacienda Drive, Suite 350 

Pleasanton, California 94588-2746 

Phone: 925.224.7780 

Fax: 925.224.7782 

Email: sblend.sblendorio@hogefenton.com 

Howard M. Levine (Oregon State Bar No. 800730) 

(Admitted Pro Hac Vice on 2/1/19) 

SUSSMAN SHANK LLP 

1000 S.W. Broadway, Suite 1400 

Portland, OR 97205-3089 

Phone: 503.227.1111 

Fax: 503.248.0130 

Email: hlevine@sussmanshank.com 

Attorneys for Wilson Utility Construction 

Company 

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 

*All papers shall be filed in the Lead 

Case No. 19-30088 (DM). 

 Case No. 19-30088 (DM) 

and 19-30089 (DM 

Chapter 11 

DECLARATION OF BRAD PROCTOR 

Date: February 27, 2019 

Time: 9:30 a.m. 

Courtroom: 17 

I, Brad Proctor, declare as follows: 

 1. I am over 18 years of age and make this declaration based on my own personal 

knowledge. If called as a witness to testify, I would testify consistent with the statements contained 

in this declaration. 

Case: 19-30088 Doc# 496-1 Filed: 02/20/19 Entered: 02/20/19 12:33:50 Page 1

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3190775 -2- 

DECLARATION OF BRAD PROCTOR

 2. I am the Vice President of Distribution Services at Wilson Construction Company 

(“Wilson Construction”) for the PG&E case. 

 3. Wilson Construction is a creditor of PG&E Company (“PG&E”). Wilson 

Construction provides the types of services the Operational Integrity Suppliers perform as described 

in or referred to in the Motion of Debtors Pursuant to 11 U.S.C. §§ 105(a), 363(b), and 503(b)(9) 

and F.R.B.P. 6003 and 6004 for Interim and Final Authority to Pay Prepetition Obligations Owed 

to Certain Safety and Reliability, Outage, and Nuclear Facility Suppliers of the Debtors’ Operational 

Integrity Suppliers as that term is defined in the Critical Vendors’ Motion. 

 4. As of the Chapter 11 filing date, PG&E owed Wilson Construction approximately 

$12.3 million. Wilson Construction is also a party with PG&E to one or more contracts governing 

the work Wilson Construction does for PG&E. Subsequent to the Chapter 11 filing date, PG&E has 

not paid Wilson Construction for any prepetition work. 

 5. Since 2012, Wilson Construction maintained a continuous presence in California as 

part of PG&E’s effort to replace and repair an aged infrastructure, as well as make improvements to 

the electrical system with respect to Reliability, Capacity, NERC requirements, and Fire Hardening 

projects. In the past three (3) years, Wilson Construction crews participated in most of the major 

Transmission reliability and NERC projects that were scheduled and awarded through the 

competitive bid process. In 2013, Wilson Construction bid for, and was awarded, a major portion 

of the Electrical Distribution Performance Partnership Pole Replacement Program ("EDPP"). 

Wilson Construction is currently in the fifth year of that program. Wilson Construction replaced 

thousands of deteriorated poles in the execution of the EDPP Partnership Program. 

 6. In 2018, Wilson Construction's line crews participated in an extensive program 

aimed at making corrections to identified EC Tag Corrections. Wilson Construction’s crews were 

successful in completing approximately 8,000 tags within the CPUC mandated time frame, and 

within PG&E’s budget. It is these very same types of EC Tag Corrections that PG&E is currently 

attempting to identify through the ongoing Inspection Program on both its Distribution and 

Transmission line infrastructures. 

 7. Throughout this period of ongoing service to PG&E, Wilson Construction was 

Case: 19-30088 Doc# 496-1 Filed: 02/20/19 Entered: 02/20/19 12:33:50 Page 2

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3190775 -3- 

DECLARATION OF BRAD PROCTOR

regularly called upon to provide emergency relief and restoration efforts for unscheduled outages 

resulting from wind, rain, snow, and fire. When necessary, and when requested to do so, Wilson 

Construction imported line crews from outside the PG&E’s service territories to supplement its 

California line crews and operational personnel. In addition to providing aid and support during 

these major calamities, Wilson Construction crews and personnel often responded to PG&E’s 

request for help on Routine Wire Down calls resulting from car hit poles, and similar disruptions to 

electrical service. Most recently, Wilson Construction crews worked on emergency storm 

restoration. Since January 1, 2019, Wilson Construction crews were deployed to respond to 

emergency storm restoration continually from as recently as January 4-8, and January 17-20, 2019. 

Wilson Construction's crews and field leadership are still working at restoration as of the time of 

this filing. 

 8. Wilson Construction's work for PG&E is often supported by select subcontractors 

who are predominately Disadvantaged Business Entities ("DBE"), who demonstrated consistent 

ability to work on short notice, especially during storm work. Each DBE is heavily dependent on 

revenue from working for Wilson Construction, and each is directly and adversely impacted by the 

bankruptcy petition. 

 9. Due to Wilson Construction's extensive knowledge of PG&E's system, and its cadre 

of seasoned field leaders and crews, Wilson Construction was recently summoned to a meeting held 

by PG&E personnel to advise it on constructability and scheduling protocols as PG&E prepares to 

undertake various fire hardening projects. Wilson Construction’s personnel includes many local 

California residents, some of whom were personally affected by the recent wildfires. Wilson 

Construction's team knows PG&E's expectations regarding safety, quality, and construction 

standards, and also understands the importance of affordability. 

// 

// 

// 

// 

// 

Case: 19-30088 Doc# 496-1 Filed: 02/20/19 Entered: 02/20/19 12:33:50 Page 3

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3190775 -4- 

DECLARATION OF BRAD PROCTOR

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

Executed on this 19th day of February, 2019, at Canby, Oregon. 

/s/ Brad Proctor

 Brad Proctor

Case: 19-30088 Doc# 496-1 Filed: 02/20/19 Entered: 02/20/19 12:33:50 Page 4

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1 I declare under penalty ofperjury that the foregoing is true and correct.

2

3

mdrrodH

4

5

6 *21003-003\DECLARATION OF BRAD PROCTOR (03099041);!

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Page 4 of 4 - WILSON UTILITY CONSTRUCTION COMPANY'S RESPONSE TO

EMERGENCY PAYMENT MOTIONS

SUSSMAN SHANK LLP, ATTORNEYS AT LAW

1000 SW BROADWAY, SUITE 1400, PORTLAND, OREGON 97205-3089

TELEPHONE (503) 227-1 11 1 | FACSIMILE (503) 248-0130

Case: 19-30088 Doc# 496-1 Filed: 02/20/19 Entered: 02/20/19 12:33:50 Page 5

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