Kenneth J. Black
Robbins Geller Rudman & Dowd LLP
One Montgomery Street, Suite 1800
San Francisco, CA 94104
July 25, 2019
VIA ONLINE SUBMISSION
Public Record Requests
California Public Utilities Commission
505 Van Ness Ave.,
San Francisco, CA 94102
Re: Public Records Act Request for Documents Pertaining to PG&E and California Wildfires
Pursuant to the California Public Records Act, Cal. Gov. Code §6250, et. seq., I request copies of the following documents from the California Public Utilities Commission (“CPUC”) pertaining to its investigation of and/or communications with Pacific Gas and Electric Company or the related PG&E Corporation (collectively, “PG&E”):
- All documents and communications produced, transmitted, or otherwise sent by the CPUC to The Wall Street Journal or any other media outlet pertaining to PG&E from 2017 to the present in response to a California Public Records Act or other records request;
- All documents and other materials related to any investigation or investigations, including any preliminary information gathering, the CPUC conducted regarding fires PG&E caused or may have caused in California between 2015 and 2018, specifically:
- The Butte Fire that started in September 2015 in Amador County, CA;
- The North Bay Fires (also known or referred to as the Northern California Wildfires or Wine County Fires) that started in October 2017 and occurred in various Northern California locations; and
- The Camp Fire that started in November 2018 near the city of Paradise, Butte County, CA.
- All documents containing or memorializing any findings that concern the investigations of the fires referenced in paragraph 2 above; and
- All other documents and communications created, produced, transmitted or sent between 2015 and the present pertaining to PG&E’s safety actions or inactions, practices and policies, including:
- The status, maintenance, and repair of PG&E’s transmission and distribution lines, towers, and other equipment;
- PG&E’s tree clearance and vegetation management;
- PG&E’s allocation of resources, such as money and personnel, to safety measures; and
- Any audits or other risk or other assessments of PG&E’s safety actions or inactions, practices and policies.
If the requested records are not available in electronic form, I agree to pay reasonable copying costs associated with the request, not to exceed $1,000 without prior authorization. Please contact me regarding any copying costs and I will make arrangements to pay them.
If my request is denied in whole or in part, please identify the CPUC’s legal basis for such denials, and if possible, an estimate of the amount of denied information. If the CPUC withholds categories of exempted information, please release the non-exempted segregable portions of such records. Finally, my firm is prepared to make an administrative appeal if the CPUC’s response is not satisfactory and would like the name of the official to whom such a request should be addressed if necessary.
If you have any questions regarding my request, please contact me by email, KennyB@rgrdlaw.com, or by phone at 415-288-4545. I look forward to your response within the next ten days, as outlined by statute.
Kenneth J. Black
 See “PG&E Knew for Years Its Lines Could Spark Wildfires, and Didn’t Fix Them,” The Wall Street Journal (July 10, 2019), https://www.wsj.com/articles/pg-e-knew-for-years-its-lines-could-spark-wildfires-and-didnt-fix-them-11562768885 (describing documents obtained by The Wall Street Journal from the CPUC).