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The Complaint alleges, “In November 2018, a fire began near Camp Creek Road in Butte County. Now dubbed the Camp Fire (hereinafter, the ‘Camp Fire’ or the ‘Fire’), it became the deadliest and most destructive wildfire in modern California history—levelling more than 150,000 acres across Butte and Plumas Counties, destroying homes, disrupting businesses, and killing dozens of people. The Camp Fire began before 6:30 a.m. on November 8, 2018 near the town of Pulga, California. It then quickly moved west, essentially erasing the town of Paradise from the map, with at least 88 lives lost, innumerable others injured, and many others missing. It destroyed nearly 14,000 homes and hundreds of commercial buildings, along with everything in them.
The Camp Fire was caused by unsafe electrical infrastructure owned, operated, and inadequately maintained by PG&E Corporation and Pacific Gas & Electric Company (together ‘PG&E’). PG&E had a duty to properly maintain its electrical infrastructure to ensure its safe operation, including by adequately designing, constructing, monitoring, maintaining, operating, repairing, replacing, and/or improving its power lines, poles, transformers, conductors, insulators, reclosers, and/or other electrical equipment. This duty included inspecting and managing vegetation and other hazards around its power lines and/or other electrical equipment, given the eminently foreseeable risk of branches or other vegetation coming into contact with this equipment and starting fires. Although PG&E knew that its infrastructure was aging, unsafe, and vulnerable to the weather and environmental conditions prevailing when the Camp Fire was ignited, PG&E did not fulfill its duties, and failed to take preventative measures in the face of known high-risk weather conditions, such as de-energizing its electrical equipment. PG&E’s dereliction of these duties resulted in the deadliest and most destructive wildfire in California history.
This catastrophe was preventable. PG&E’s failing infrastructure and its inadequate efforts to maintain its equipment and mitigate risk have resulted in prior tragedies, and, unsurprisingly, PG&E has been sanctioned repeatedly for misconduct that bears a striking resemblance to that pled here. Despite notice of its past failures and even public reprimand, PG&E has continued to cut corners and elevate profits over public safety, and it has continued to operate dangerous equipment without adequate risk management practices in place.”
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