PG&E Corporation

Phase A — Understand the business

Company Overview

PG&E Corporation is a holding company whose sole material asset is Pacific Gas and Electric Company — the largest combined electric-and-gas investor-owned utility in the United States by customer count, serving ~16 million people across a 70,000-square-mile service territory in northern and central California. It is, in plain terms, a regulated monopoly that earns a CPUC-authorized rate of return on a giant and rapidly growing capital base, plus a separate FERC-regulated transmission business.

How it actually makes money: the CPUC (California Public Utilities Commission) sets a revenue requirement every four years in a General Rate Case (GRC), calculated as operating costs plus (authorized rate of return × rate base). Rate base is the depreciated value of the Utility's poles, wires, pipes, substations and generation. The more capital PG&E prudently invests, the larger the rate base, and the more dollars of earnings it is permitted to collect. This is the entire engine — it is a spread business on regulated capital, not a competitive enterprise.

• Products/services: electric distribution + generation, electric transmission (FERC-jurisdictional, formula-rate), natural gas distribution, gas transmission & storage. Reported as one segment.
• Customers: ~5.5M electric + ~4.5M gas accounts. FY2025 electric revenue split: residential $6.98B, commercial $7.02B, industrial $1.93B, agricultural $1.83B. No customer concentration — it is a captive ratepayer base.
• Suppliers: power-purchase counterparties (renewables + storage developers), gas suppliers, and the contractors building the grid-hardening program. No single-supplier dependency that matters.
• Key payment terms / structure: revenue is regulated cost-of-service, not contractual — collected through tariff rates. Crucially, much of the revenue runs through regulatory balancing accounts that true-up over- or under-collection (e.g. FY2025 electric balancing accounts +$389M vs −$830M in 2024), so reported revenue is noisy quarter-to-quarter but economically smoothed.

The defining fact about this business is not on the income statement: it operates in California, the only U.S. jurisdiction where courts apply inverse condemnation — strict liability for wildfire damage caused by utility equipment, regardless of fault. That single doctrine drove PG&E into Chapter 11 in 2019 and remains the master risk over everything below.

Supply Chain

A regulated wires-and-pipes utility has a "supply chain" that is really a physical delivery chain + a regulatory-capital supply chain. Named stakeholders along both:

Physical / operational chain:

• Upstream energy inputs: wholesale power via the CAISO (California Independent System Operator) market; PPAs with renewable + storage developers; natural gas from interstate pipelines into PG&E's own gas transmission & storage system.
• The Utility (midstream): ~$141.6B of total assets, of which the regulated rate base is the productive core. Operates the largest combined T&D system in the U.S.
• Downstream: ~16M end customers (residential, commercial, industrial, agricultural), plus a fast-emerging buyer class — hyperscale data centers seeking large new interconnections (named explicitly as a load-growth driver).

Regulatory-capital supply chain (the chain that actually feeds earnings):

• CPUC — sets the GRC revenue requirement + cost-of-capital (authorized ROE/equity ratio). The single most important counterparty.
• FERC — sets transmission ROE via the formula rate (TO rate case).
• OEIS (Office of Energy Infrastructure Safety) — issues the annual safety certification that unlocks AB 1054/SB 254 liability protections. This is a chokepoint: lose the certification and the prudency presumption and disallowance cap evaporate.
• Wildfire Fund / Continuation Account administrator — the statewide backstop pools that reimburse catastrophic wildfire claims. Shared with Edison (SCE) and Sempra (SDG&E) — meaning PG&E's downside is partly hostage to its competitors' fires (see Lens 5/10).
• Capital markets — as a chronically cash-flow-negative-after-capex entity, PG&E is structurally dependent on continuous access to investment-grade debt and periodic equity.

Chokepoints / single-source dependencies: (1) the OEIS safety certification; (2) the CPUC's prudency determinations — every dollar of wildfire-mitigation spend is incurred before it is known to be recoverable; (3) shared-pool exposure to other utilities' fires via the Wildfire Fund.

Competitive Advantages (moats)

PG&E's moat is the strongest structural moat that exists — a legal, regulated monopoly franchise — wrapped around the weakest balance-sheet/liability profile of any large U.S. utility. Both halves are true simultaneously.

• Monopoly franchise (the moat): no competitor can string a parallel grid. Customers are captive. Demand is inelastic and now growing after a decade of flat load, thanks to electrification + data centers.
• Scale: largest combined IOU in the U.S.; the $73B five-year capital plan gives it more rate-base-growth runwayRunwayHow long the cash lasts at the current rate of spending. It shortens the moment spending rises, which is why a figure taken from a quiet quarter flatters. than almost any peer.
• Switching costs / network effects: total — there is no switch to make.
• Bargaining power — this is where the moat inverts. Against customers, PG&E has pricing power only to the extent the CPUC grants it, and affordability is now a binding political constraint (PG&E has committed to capping average annual rate increases at 3% and bundled residential rates are down 23% since 2024 for vulnerable customers). Against the CPUC and the courts, PG&E has almost no bargaining power — inverse condemnation imposes liability "regardless of fault," and the regulator can deny cost recovery on prudency grounds.

Threats to the moat: (1) Municipalization — San Francisco has petitioned the CPUC to value and acquire PG&E's in-city electric assets via eminent domain; success would carve assets out of rate base. (2) Gas-system stranding — California building-electrification mandates shrink the gas customer base, risking "used and useful" write-downs of gas assets. (3) Customer flight — high rates → bypass/self-generation → death-spiral risk. None is acute, but all chip at the franchise.

Net: the moat is real and durable, but it is a low-bargaining-power moat. PG&E earns a regulated return, not an excess return — and even that return is contingent on prudency and political tolerance.

Segments

PG&E reports as one segment, so there is no segment EBITDA breakout. The meaningful disaggregation is electric vs. gas revenue and by customer class:

All figures.

Reading the trend: revenue growth is deliberately muted (~2%) because affordability caps suppress headline rate growth — but operating income grew 6% and net income 5%, because the earnings driver is rate-base growth and operating-cost reduction (the "Lean" program), not revenue. The economically correct lens for a utility is rate base, not revenue: the $73B capital plan implies high-single-digit annual rate-base growth, which is what underwrites the 9%+ EPS growth guidance. Gas is the soft spot — flat-to-declining and structurally challenged by electrification. Electric is the growth engine, now turbocharged by data-center interconnection demand.

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Phase B — Measure performance

Earnings Result (latest print — Q1 2026)

The most recent print (Q1 2026, quarter ended 2026-03-31) was strong on the surface and reassuring on the controllables:

• Revenue $6,881M, +15% YoY (vs $5,983M Q1 2025). Much of the jump is regulatory balancing-account timing (electric balancing accounts +$606M vs +$66M), not underlying demand — read it cautiously.
• Operating income $1,478M, +20%; net income $954M, +37% (vs $695M).
• Diluted EPS $0.39 vs $0.28 (+39%). (GAAP; the company guides on a non-GAAP "core EPS" basis.)
• Management reaffirmed 2026 core EPS guidance of $1.64–$1.66 and the 9%+ annual EPS growth through 2030.
• The standout disclosure was a negative one: Wildfire Fund expense rose +$26M (+34%) YoY due to accelerated amortization of the Wildfire Fund asset triggered by SCE's Eaton-fire settlements — $27M of acceleration in the quarter, $102M total Wildfire Fund expense. This is the Eaton contagion showing up in PG&E's P&L despite PG&E not having caused the fire.

Balance-sheet flags: PG&E generated $9,035M operating cash flow in FY2025 (+9%) but spent $13.4B on capex — a structural ~$4B+ annual funding gap covered by debt and (historically) equity. Cash on hand is a thin $360M. Total debt ≈ $60.9B ($57.4B long-term + $2.7B short-term + $0.8B current) against $32.8B equity — a ~65% debt / 35% equity capital structure, heavily levered even for a utility.

Market reaction: the stock did not reward the operational beat — PCG fell 6.2% on 2026-04-13 as wildfire-liability worries and downgrade chatter (UBS to Neutral) overwhelmed the print. That is the entire investment story in one data point: operations are fine; the market is trading the tail.

Earnings Calls (sentiment trend)

No transcripts on the local shelf (transcripts/ empty), so this is ``-grounded from the Q4 2025 and Q1 2026 calls.

• Consistent management focus across the last 3–4 calls: (1) safety/operational turnaround ("Lean" operating system, undergrounding miles completed — ~1,000 miles of high-risk lines as of Q3 2025); (2) affordability (capping bill increases, advertising the −23% bundled-residential-rate stat); (3) the $73B capital plan with "no new equity through 2030" — repeated as a deliberate de-risking signal to equity holders; (4) data-center load growth as the new bull narrative.
• Tone shift: management's posture has moved from defensive/rebuilding (2021–2023, post-bankruptcy) to confidently promotional (2025–2026) — they now lead with growth and a clean equity story. The thing they say less of: existential wildfire framing. The thing the market still hears loudest: wildfire.
• The gap between management's confident tone and the stock's discounted multiple is the single most important sentiment signal in this name.

Comps

PCG + key regulated-utility peers. Multiples are `` with date; ROE from filings/web where available. No multiple fabricated — n/a where not sourced.

PCG fwd P/E: $17.26 / ~$1.65 ≈ 10.5x. Peer multiples. PCG ROE ≈ income-avail-common $2.59B / ~$31B avg common equity ≈ 8.3%; authorized 2026 ROE 9.98% (it under-earns its authorized return — typical of a utility still rebuilding).

The whole table says one thing: PCG trades at ~10x vs. a peer group at 15–20x — roughly a 40% discount. The discount is entirely the California-wildfire risk premium. Edison (EIX) is the most instructive comp: it trades even cheaper because it is the utility with the open Eaton-fire liability — confirming the market prices these names on liability exposure, not on rate-base growth. PCG sits in between: de-risked relative to EIX, penalized relative to SO/SRE.

Stock-Price Catalysts (last ~5 years)

PCG's >5% moves cluster around wildfire/legislative events and bankruptcy-recovery milestones, almost never around earnings beats:

• 2019–2020: Chapter 11 filing and emergence (June 2020) — the defining repricing.
• 2021–2024: Dixie fire (2021), Mosquito fire (2022) accruals; index inclusion (S&P 500 added PCG in 2022); steady recovery as bankruptcy receded.
• Mar 2025: Moody's upgrade (Utility first-mortgage bonds to Baa1; HoldCo senior secured to Ba2) on reduced wildfire credit risk — a positive catalyst.
• Jan 2025 onward — the Eaton fire (SCE-caused): reopened the "shared Wildfire Fund depletion" fear; PCG repeatedly sold off on Eaton headlines despite no PCG fault.
• Sept 2025 — SB 254 signed: $18B Continuation Account expansion — structurally positive, but the market's reaction was muted/mixed because of the rate-base-exclusion cost (see Lens 11).
• Apr 2026: −6.2% on wildfire-fund worries + UBS downgrade.

Pattern → the market reacts to (1) California wildfire-policy news and (2) any fire, anywhere in the state, that could drain the shared fund. It does not meaningfully reward operational or rate-base execution. For a position, this means the catalysts that matter are exogenous (fire season, CAL FIRE/Eaton determinations, CPUC prudency rulings), not the quarterly cadence.

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Phase C — Judge people & books

Management

• CEO — Patricia "Patti" Poppe (PG&E Corp, since Jan 2021). Hired five months after bankruptcy emergence; prior CEO of CMS Energy / Consumers Energy (2016–2020), where she built a recognized safety-and-operational track record (safety incidents −70%). Track record at PG&E (quantified): restored investment-grade status on the Utility's first-mortgage bonds (Moody's Baa1, Mar 2025); income avail. for common from ~$0.4B-loss-adjacent recovery to $2.59B (FY2025); executed the "Lean" cost program; established the $73B capital plan with a no-new-equity financing structure — a genuine de-risking of the equity story.
• Red flag — compensation optics: Poppe's 2021 total comp was reported at ~$51.2M — wildly above the ~$4M utility-CEO norm and a recurring point of public/political criticism in a state obsessed with PG&E affordability. For a company that asks ratepayers to absorb wildfire-mitigation costs, this is a live reputational/regulatory liability, not just an optics quibble.
• CFO — Carolyn J. Burke (since May 2023), ex-Chevron Phillips Chemical CFO.
• New Utility CEO — Sumeet Singh (Pacific Gas & Electric Co., since Jan 2026) — promoted from EVP Energy Delivery; a 2026 leadership reorg the market reacted positively to.
• Capital allocation: classic regulated-utility profile — reinvest everything into rate base, minimal dividend (only ~$0.20/yr, ~1.2% yield, ramping toward a 20% payout ratio by 2028). The discipline is the no-new-equity-through-2030 commitment, which protects existing holders from dilutionDilutionIssuing new shares, so each existing share owns a smaller slice of the same company. — a credible, well-telegraphed allocation stance.
• Insider ownership / skin in the game: no our figures on the shelf; the 10-KForm 10-KA company’s audited annual report to the US regulator. The most complete thing it publishes. notes Poppe and Singh adopted Rule 10b5-1 sale plans in late 2025 (Poppe up to 62,500 shares; Singh PSU-linked) — routine, modest, but worth tracking for tone.
• Archetype: professional turnaround manager (not founder). Correct fit for a post-bankruptcy regulated utility whose job is operational rebuild + capital-markets credibility, both of which she has delivered.

Forensic Red Flags

PG&E's accounting is dominated by regulatory and wildfire estimates — that is where the bodies would be buried, not in revenue recognition.

• Regulatory assets/liabilities (the big one): noncurrent regulatory liabilities of $20.2B, including a $6.0B SB 901 securitization balance and a $5.09B SB 901 securitization regulatory asset. These are real, CPUC-blessed, and amortize over the recovery-bond life — but they are estimates contingent on continued regulatory recovery. A prudency disallowance would impair them.
• Wildfire Fund asset — accelerated-amortization risk (the live one): PG&E carries a ~$3.9B Wildfire Fund asset ($295M current + $3.6B noncurrent). Management discloses the rule explicitly: for every $5B of Wildfire Fund receivables booked by any participating utility, PG&E records ~$1B of accelerated amortization. SCE's Eaton settlements already triggered $27M of acceleration in Q1 2026, and management warns the asset "could be amortized down to zero in the near future." This is a non-cash but earnings-real hit that PG&E cannot control — it is set by Edison's fire.
• Wildfire liability estimates: accrued losses of $1.325B (2019 Kincade), $2.15B (2021 Dixie), $350M (2022 Mosquito) — explicitly excluding categories "not reasonably estimable". Recorded recoveries ($632M Dixie + $61M Mosquito via FERC/WEMA; $1.15B Dixie Wildfire Fund receivable, $851M received) are themselves contingent on prudency findings. Liabilities exceed insurance ($430M Kincade, $521M Dixie coverage) — the gap is the recovery bet.
• Cash flow vs. earnings: operating cash flow ($9.0B) comfortably exceeds net income ($2.7B) — normal for a depreciation-heavy utility, no divergence flag. But FCF is deeply negative after $13.4B capex — the company does not self-fund; it is a perpetual capital-markets borrower.
• Leverage: $11.7B of long-term debt sits in VIEs (securitization structures). Total debt ≈ $60.9B; HoldCo unsecured remains below investment grade at one agency. High leverage is the structural fragility.
• SBC: immaterial to a utility this size ($82M amortization FY2025) — no non-GAAP flattering concern.

Regulatory findings (required):

• SEC Litigation Releases & AAERs: None. Verified via SEC EDGAR EFTS (LR + AAER) over 2021-06-30 → 2026-06-30.
• Item 3 Legal Proceedings (10-K): dominated by the wildfire matters above (Kincade, Dixie, Mosquito) plus Wildfire-Related Securities Claims and ongoing CPUC investigations/enforcement exposure. PG&E "has been the subject of investigations, regulatory enforcement actions, and criminal proceedings in connection with wildfires" — a reference to the historical Camp/Kincade criminal exposure; no new criminal action disclosed for the current fires.
• Non-SEC enforcement (web): PG&E's history includes the felony probation (2017 San Bruno pipeline), Camp Fire guilty plea (2020), and continuous CPUC oversight — the heaviest regulatory rap sheet of any U.S. utility. No new material non-SEC enforcement action surfaced for FY2025/Q1-2026 beyond the standing wildfire/CPUC matters.

Net forensic read: the accounting is clean of fraud markers but saturated with regulatory contingency. The risk is not manipulation — it is that a single CPUC prudency ruling or a single fire can impair billions of carrying value overnight. The Eaton-driven Wildfire Fund amortization is the clearest near-term example.

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Phase D — Project & stress-test

Forward Projection (FY2026–FY2028 core EPS)

Built bottom-up from FY2025 actuals + management guidance. PG&E guides on non-GAAP "core EPS."

Anchors:

• FY2025 core EPS ≈ $1.49–$1.51.
• 2026 core EPS guidance: $1.64–$1.66 (midpoint $1.65).
• Long-term guidance: ≥9% annual core EPS growth 2027–2030; EPS target ~$2.33 by 2030; $73B capex; no new equity through 2030; 20% payout by 2028.

`` arithmetic: Base FY2027 = $1.65 × 1.09 = $1.80; FY2028 = $1.80 × 1.09 = $1.96. Bear path assumes the 2027 GRC ($16.64B revenue-requirement request ) is cut materially on affordability grounds + persistent Wildfire-Fund amortization, compressing growth to ~6%. Bull assumes the no-equity plan holds, data-center load adds incremental rate base, and the multiple (not just EPS) rerates.

The projection's honest caveat: EPS growth here is unusually visible (regulated, guided, capital-plan-backed) — the 9% is among the more credible growth numbers in the utility sector. The uncertainty is almost entirely in the multiple, not the EPS — which is why the valuation work (Lens 7/12) matters more than the model.

Brier forecast — NOT logged (per --watchlist rule: skip our model create in the breadth loop). If promoted to a thesis, the loggable base call would be: "PCG FY2026 non-GAAP core EPS ≥ $1.64, p≈0.90, resolves 2026-12-31."

Bull vs Bear

Bull case. PG&E is a regulated monopoly with top-tier, highly-visible rate-base and EPS growth (9%+ to 2030, EPS to ~$2.33), a fully-funded $73B capital plan that requires no dilutive equity through 2030, and an emerging data-center load-growth tailwind that adds rate base without raising customer bills. AB 1054 + SB 254 have built a $18B+ statewide wildfire backstop and a disallowance cap (20% of equity T&D rate base) that structurally limits the catastrophic-liability scenario that caused the 2019 bankruptcy. Moody's has already started upgrading (Utility bonds to Baa1). Yet the stock trades at ~10x vs. peers at 15–20x. If California gets through a fire season without a PG&E-caused catastrophe and the CPUC/legislature continue to reform liability, the multiple rerates toward the low-$20s — analyst median target $23, range $19–27, with 13 Buy / 4 Hold / 0 Sell. The bull thesis is "the discount is mispriced; you are paid to wait for the rerate."

Bear case. Three risks that could permanently impair or durably suppress the equity:

1. California inverse condemnation is unchanged — strict liability "regardless of fault" survives. One PG&E-caused catastrophic fire in a high-wind year reopens the existential question; the disallowance cap only protects if the OEIS safety certification is intact and conduct wasn't "conscious or willful disregard."
2. Shared-fund contagion + the SB 254 rate-base tax. The Eaton fire is draining the shared Wildfire Fund through no fault of PG&E's — PG&E books ~$1B accelerated amortization per $5B of receivables, and the asset "could be amortized to zero in the near future". Worse, SB 254 forces the first $2.9B of fire-mitigation capex out of equity rate base (financed by securitization) — meaning PG&E must spend that capital but earns no shareholder return on it. That is a direct, legislated haircut to the growth algorithm.
3. Leverage + affordability squeeze. ~$60.9B debt vs. $32.8B equity, HoldCo unsecured still junk, $13.4B annual capex against $9.0B operating cash flow — a perpetual borrower exposed to rate cycles. Simultaneously, a binding 3% bill-cap and a CPUC that adjudicates on affordability can cut the authorized revenue/capital that the whole EPS-growth story depends on.

Pre-mortem (18 months out, thesis broke): It is late 2027. A dry, high-wind autumn produced a PG&E-equipment-linked fire in an HFTD; the CPUC opened a prudency investigation; the Wildfire Fund — already drained by Eaton — looks insufficient; Moody's reversed the HoldCo to a downgrade watch; the 2027 GRC came in light on affordability grounds. The multiple de-rated to 8x and the EPS-growth algorithm got cut to mid-single-digits. The stock is at $13.

Are multiples too high? No — the opposite. At ~10x, PCG is the cheapest large regulated utility in the U.S. The debate is whether it is cheap-for-a-reason (permanent California risk premium) or mispriced (de-risked but stigmatized). The honest answer: it is a real risk premium that is probably too large given AB 1054/SB 254, but the catalyst to close it is exogenous and slow.

Contrarian view (what the market refuses to see): the market is still trading PG&E as the 2018-Camp-Fire company, but the legislative architecture has fundamentally changed the payoff distribution — the left tail is capped (disallowance cap, Wildfire Fund, Continuation Account) in a way it wasn't pre-AB 1054. The market is paying for a bankruptcy-probability that the law has materially reduced. The flip side the bulls refuse to see: SB 254's rate-base exclusion is a quiet, permanent tax on the growth story that partly offsets the de-risking.

Devil's Advocate (short-seller)

Dismantling the bull case:

• What structurally breaks the money machine: a single catastrophic, PG&E-caused wildfire in a year California's shared funds are already depleted. The earnings are regulated and stable until they aren't — the distribution is not normal, it has a fat left tail that no amount of 9%-EPS-growth modeling captures. Inverse condemnation means fault is irrelevant — the company can be liable for a fire it didn't negligently cause.
• Where the bull math is quietly wrong: the "$73B capex → 9% EPS growth" story assumes PG&E earns its authorized return on all of it. SB 254 explicitly excludes the first $2.9B of fire-mitigation capex from equity rate base — PG&E spends it, ratepayers fund the securitization, shareholders earn nothing on it. The growth algorithm has a legislated leak the bulls under-discount.
• The shared-fund hostage problem: PG&E's reported earnings are partly a function of Edison's fire losses. The Q1 2026 accelerated amortization happened because SCE settled Eaton claims. A short can model PG&E's downside off another company's litigation — and the Wildfire Fund asset can go to zero.
• Most dangerous competitor bulls underestimate: not a competitor — the California political/regulatory process itself. Affordability is now the binding constraint; the CPUC's incentive is to protect ratepayers, and the legislature can re-tax shareholders (SB 254 just did). Plus municipalization (San Francisco's eminent-domain petition) can carve out the lowest-cost-to-serve rate base.
• Worst capital-allocation/governance optics: a $51M CEO comp package at a company pleading affordability to regulators — a gift to consumer advocates and a recurring headline risk.
• What must hold for today's ~$17 price: (1) no PG&E-caused catastrophic fire for the foreseeable horizon; (2) CPUC keeps granting prudency recovery on wildfire-mitigation spend; (3) the 2027 GRC funds the capital plan; (4) capital markets stay open to a junk-HoldCo borrower. Break any one and the discount widens, not narrows.
• −20–30% growth-disappointment scenario: if EPS growth is cut from 9% to ~6% (soft GRC + amortization drag), FY2028 base falls from ~$1.96 to ~$1.85, and the multiple likely compresses on the disappointment — a double hit. The asymmetry of a regulated utility is that the upside is capped (you earn the authorized ROE) but the downside (a fire, a disallowance) is not.
• The single permanent-impairment scenario: a "conscious or willful disregard" finding on a future fire — which voids the disallowance cap entirely and re-creates 2019. Plausibility: low in any given year, but cumulative over a multi-year hold in the most fire-prone U.S. service territory, non-trivial.

Management Questions (ordered by information value)

1. With SB 254 excluding the first $2.9B of fire-mitigation capex from equity rate base, what is the resulting drag on your 9%+ EPS-growth algorithm, and is the 9% net or gross of that exclusion?
2. How should investors think about the path of Wildfire Fund asset amortization given Eaton — what is the worst-case non-cash EPS hit if the asset amortizes to zero, and over what period?
3. What specific, measurable conditions would have to be met for you to declare the wildfire tail-risk "structurally resolved" — and what is your own estimate of when the market closes the ~10x-to-peer discount?
4. The 2027 GRC requests a $16.64B revenue requirement against a binding affordability mandate. What is your downside revenue-requirement scenario, and what does the capital plan look like if the CPUC cuts it 10–15%?
5. How firm is the "no new equity through 2030" commitment under a stress scenario (a new fire accrual, a credit-rating action, a GRC shortfall) — at what trigger would you revisit it?
6. What is your realistic timeline and cost exposure for the San Francisco municipalization petition, and how much rate base is at risk?
7. Quantify the data-center load-growth opportunity: how many GW of signed/advanced interconnections, what incremental rate base, and how much is in the $73B plan vs. upside to it?
8. What would it take for the HoldCo unsecured rating to reach investment grade, and what is the cost-of-capital benefit when it does?
9. How exposed is the gas-distribution rate base to "used and useful" stranding as electrification mandates advance, and what is the decommissioning-cost liability?
10. On the disallowance cap (20% of equity T&D rate base) — what dollar figure does that represent today, and how does it scale with the capital plan?
11. What is your self-insurance + Wildfire Fund + Continuation Account coverage stack for a single catastrophic-fire year, and where is the first dollar of shareholder exposure?
12. How do you defend the executive-compensation structure to the CPUC and ratepayers while asking them to absorb mitigation costs?
13. What is your undergrounding cost-per-mile trajectory, and is the 10-year Electric Undergrounding Plan economically recoverable at scale?
14. How much of the FY2026 +15% revenue and +37% net-income growth is regulatory-balancing-account timing vs. durable rate-base earnings?
15. What is your contingency if a future fire produces a "conscious or willful disregard" finding that voids the disallowance cap?

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