PG&E : October 18, 2021 Response to order for further responses regarding Dixie Fire

Case 3:14-cr-00175-WHA Document 1493 Filed 10/18/21 Page 1 of 9

1. JENNER & BLOCK LLP Reid J. Schar (pro hac vice)
2. [e-mail]
3. 353 N. Clark Street Chicago, IL 60654-3456
4. Telephone: [phone]
   Facsimile: [phone]

5	CLARENCE DYER & COHEN LLP
6
Kate Dyer (Bar No. 171891)
7	[e-mail]
899 Ellis Street
8	San Francisco, CA 94109-7807
9	Telephone: [phone]
Facsimile: [phone]
10	CRAVATH, SWAINE & MOORE LLP
11	Kevin J. Orsini (pro hac vice)
[e-mail]
12	825 Eighth Avenue
13	New York, NY 10019
Telephone: [phone]
14	Facsimile: [phone]
15	Attorneys for Defendant PACIFIC GAS AND ELECTRIC
COMPANY
16
17	UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
18	SAN FRANCISCO DIVISION
19
20	UNITED STATES OF AMERICA,		Case No. 14-CR-00175-WHA
21	Plaintiff,		RESPONSE TO ORDER FOR
		FURTHER RESPONSES RE DIXIE
22	v.		FIRE
23		Judge: Hon. William Alsup
PACIFIC GAS AND ELECTRIC COMPANY,
24
Defendant.
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RESPONSE TO ORDER FOR FURTHER RESPONSES RE DIXIE FIRE

Case No. 14-CR-00175-WHA

Case 3:14-cr-00175-WHA Document 1493 Filed 10/18/21 Page 2 of 9

1	Defendant Pacific Gas and Electric Company ("PG&E") respectfully submits this

1. response to the Court's October 13, 2021 order requesting information regarding the Dixie Fire (Dkt.
2. 1492).

4	Question 20:
5	To the data produced at Dkt. No. 1444-5 at 7, provide pre-fault data going
6	back to 6:00 AM on July 12, 2021, for all three phases of the Bucks Creek
1101 line. Reproduce the old data. Adjust the new chart so that each row
7	represents a singular time.
PG&E Response:
8
Please see Attachment 1 hereto for the requested data in the requested format.
9
Question 21:
10
Did the chart produced at 1444-5 at 7 give readings in amperes or
11
kiloamperes? Did it give times in UCT or local time?

12 PG&E Response:

13	The data produced at Dkt. No. 1444-5 at 7 (a) gives readings in amperes and (b) gives
14	times in local time.
15	Question 22:
16	In that chart, amps appear to go to zero on Phase C at 6:48 a.m. on July
17	13. They appear to go to zero at 18:09 on Phase A and at 18:55 on Phase
C. Clarify the meaning of the columns ending.

18 PG&E Response:

19	As explained in paragraph 4 of Dkt. No. 1444-5:
20	Line reclosers transmit to the company's RT SCADA system a variety of
21	data at periodic intervals of between approximately 15 and 30 seconds. If
the data read at any particular time interval differs from the data
22	read at the immediately preceding time interval, the data point is
recorded in the company's PI Historian database. This includes the
23	data point regarding the current level on each phase of the distribution
circuit on which the line recloser operates.

1. (emphasis added). Consequently, the absence of an entry in the referenced table for each phase after
2. the noted times does not indicate that the amps went to zero at that time; rather, the absence of any
3. entry after the last noted times for each phase indicates that no additional data were recorded in the
4. PI Historian database for the remainder of July 13. Based on PG&E's understanding of the PI

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RESPONSE TO ORDER FOR FURTHER RESPONSES RE DIXIE FIRE

Case No. 14-CR-00175-WHA

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RESPONSE TO ORDER FOR FURTHER RESPONSES RE DIXIE FIRE

Case No. 14-CR-00175-WHA

/s/ Kevin J. Orsini

Kevin J. Orsini (pro hac vice)

By:

CRAVATH, SWAINE & MOORE LLP

/s/ Reid J. Schar

Reid J. Schar (pro hac vice)

By:

JENNER & BLOCK LLP

Dated: October 18, 2021

Respectfully Submitted,

(approximately every 15 to 30 seconds) the same current level for each phase as it had reported at the time of the last recorded entry for that phase.1 If the amp level at the recloser's location had dropped to zero - or had changed at the reporting intervals to any value other than the previously recorded level - that change would be recorded. The data indicate that measured amps remained at the same level at the recloser's location for the remainder of the day after the last recorded entry for each phase.2 Similar periods of stable amp level measurements (resulting in no recorded data) can be seen, for example, on Phase A from 7/12/21 20:39 to 7/12/21 6:48; on Phase B from 7/12/21 17:08 to 7/13/21 4:35; and on Phase C from 7/12/21 5:54 to 7/12/21 20:36. The PI Historian database did not record zero amps on any of the three phases until 12:04 on July 14, at which point it recorded zero amps on all three phases. PG&E has added to Attachment 1 the data on each phase to 12:04 on July 14. The outage log reflects that the recloser was opened at CAL FIRE's request at 20:00 on July 14.

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24 1 The same is true for Attachment 1 hereto.

25 2 As described, the SCADA system only communicated with the line recloser at periodic (albeit 26 relatively short) intervals. The SCADA system did not measure current between those periodic

intervals; during those intervals current levels could go up or down and then return to the previously

27 recorded value.

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Historian software program, that means that the line recloser thereafter periodically reported

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Case 3:14-cr-00175-WHA Document 1493 Filed 10/18/21 Page 4 of 9

CLARENCE DYER & COHEN LLP

By: /s/ Kate Dyer

Kate Dyer (Bar No. 171891)

Attorneys for Defendant PACIFIC GAS AND

ELECTRIC COMPANY

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RESPONSE TO ORDER FOR FURTHER RESPONSES RE DIXIE FIRE

Case No. 14-CR-00175-WHA

Case 3:14-cr-00175-WHA Document 1493 Filed 10/18/21 Page 5 of 9

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RESPONSE TO ORDER FOR FURTHER RESPONSES RE DIXIE FIRE

Case No. 14-CR-00175-WHA