PG&E : November 23, 2021 Request For Critiques

United States District Court Northern District of California

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Case 3:14-cr-00175-WHA Document 1524 Filed 11/23/21 Page 1 of 2

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA,
Plaintiff,	No. CR 14-00175 WHA
v.
PACIFIC GAS AND ELECTRIC	REQUEST FOR CRITIQUES
COMPANY,
Defendant.

The Court thanks the Monitor and PG&E for their recent reports and responses. These have important information for the public and the regulators. To assist in clarifying that information, by DECEMBER 16 AT NOON, the Monitor and PG&E are requested to critique each other's report/response as follows. The Monitor's report, submitted November 19, 2021, is appended hereto. Please read the other's report/response and identify those passages or portions thereof, if any, that you believe are misleading, inaccurate, incomplete, or in need of clarification and/or important to the public's understanding of the issues involved. Please reproduce those passages or portions to be critiqued along with your response.

PG&E should, for example, state whether it's true, as stated by the Monitor at page 45, that "multiple" times between 2019 and 2021, PG&E failed to alert all account holders in advance of impending PSPS events. For another example, PG&E should state whether it's true that "without counting projects built to the fire rebuild standard toward its annual system

United States District Court Northern District of California

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Case 3:14-cr-00175-WHA Document 1524 Filed 11/23/21 Page 2 of 2

hardening goal . . . PG&E would not have satisfied its annual system hardening WMP target for 2019 or 2020" (pages 43-44). Additionally, PG&E should clarify what it meant by the phrase "stood up" at page 24. (Possibly, it was an editing error.)

Please limit these critiques to 20 pages plus 10 pages of exhibits. The United States is invited to file its own critique of both reports/responses (up to the same page limits as to each) by the same date. Also, it would be useful for PG&E and the Monitor to file a separate agreed- on glossary of terms explaining in a single sentence terms like "DIRT," etc. PG&E shall file its critique as a public document. The Monitor's shall be filed publicly as well.

IT IS SO ORDERED.

Dated: November 23, 2021.

WILLIAM ALSUP

UNITED STATES DISTRICT JUDGE

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