Earnings Call Transcript
PG&E Corp (PCG)
Earnings Call Transcript - PCG Q1 2021
Operator, Operator
Greetings, thank you for standing by, and welcome to the PG&E Corporation First Quarter 2021 Earnings Call. I would now like to hand the conference over to Matt Fallon, Senior Director of Investor Relations. Please go ahead.
Matt Fallon, Senior Director of Investor Relations
Good morning, everyone, and thank you for participating in PG&E's first quarter earnings call. Joining us today are Patti Poppe, our Chief Executive Officer; and Chris Foster, Executive Vice President and Chief Financial Officer. I want to remind you that today's discussion will include forward-looking statements about our outlook for future financial results, which are based on assumptions, forecasts, expectations and information currently available to management. Some of the important factors that could affect the company's actual financial results are described on the second page of today's first quarter earnings call presentation. The presentation also includes a reconciliation between non-GAAP and GAAP measures that can be found online, along with other information at investor.pgecorp.com. We also encourage you to review our quarterly report on Form 10-Q for the quarter ended March 31, 2021. Before I turn it over to Patti, I'm excited to announce that we'll be hosting you for our Investor Day on August 9 here in California. Please keep an eye out for the invite. With that, I'll turn it over to Patti.
Patti Poppe, CEO
Thank you, Matt. Good morning, everybody. It's so great to be with you for our first quarter earnings call. We delivered solid Q1 non-GAAP core earnings of $0.23 per share in our first quarter. This morning, we're reaffirming our 2021 non-GAAP core earnings per share guidance of $0.95 to $1.05. We're also maintaining our longer-term 2021 to 2025 non-GAAP core earnings per share CAGR of 10% that we gave on the Q4 call. We're holding our equity guidance range for 2021 at 0 to $400 million. We're taking a conservative approach as we await a final decision on the securitization order from the CPUC and as we continue to make progress on legacy issues. Rest assured, Chris and I are laser-focused on minimizing our 2021 equity needs. We want you to have confidence in our forecast, and we have several more months this year to make progress on the equity range. Chris will describe the financials a bit more in a few minutes. As I finished up my first 100-day listening tour, we've accelerated our move from listening to action. Our priorities fall into three categories: first, to end utility-caused catastrophic wildfires by demanding excellence of ourselves in our wildfire prevention work; second, to create a culture of performance by deploying our lean operating system across the enterprise during 2021; and third, by continuing to lead in the clean energy transition through the latest technologies in battery storage, electric vehicle infrastructure, and microgrid solutions. Our near and long-term financial performance is inextricably linked to these three focus areas. We can deliver on these objectives and thereby serve our customers and our investors better than ever before. Thankfully, I don't need to do this alone. I've hired key senior leaders who represent the best in the business. We added some very experienced senior leaders to the PG&E team, who we highlighted on the Q4 call. Since then, we've announced additional new senior leaders to round out our team, including Chris Foster as CFO; Jason Glickman, as EVP of Engineering, Planning and Strategy; Carla Peterman, as EVP of Corporate Affairs; and Wade Smith, as Head of Electric Operations. I'm pleased with the team that we have here at PG&E, and I would stack our operating experience up against anyone. The common thread in all of our leaders is a tenacity to perform and the skills to deliver. Before diving into the substantial changes we're making here at PG&E, there's something I'd like to address right up front. Earlier this month, the Sonoma County district attorney filed criminal charges related to the Kincade Fire against the company. We do not agree with these charges, and we'll defend them in legal proceedings. In the meantime, we'll make it right by working to resolve victim's claims fairly and justly. And each day, we'll continue to make it safe by prioritizing the work that needs to be done to deliver energy to our customers. One organizational enhancement I'd like to highlight is our interim wildfire risk organization announced last month, led by Sumeet Singh. This team has been instrumental in responding to the criticism we faced on our enhanced vegetation work. As a part of our lean operating system implementation, the federal monitor and the governor's operational observer are included in our daily operating reviews associated with wildfire work. You may wonder, won't it take years to implement lean? The answer is no. We've already started our implementation on our most important work, and the system will provide benefits immediately as well as for years to come as we grow our capability and our maturity. One simple example happened in the very first week of our daily operating reviews; we were off track on our distribution sectionalizing device installations. We completed 12 devices as compared to a goal of 30. And as a result of the daily operating review, we gained visibility of the problem and built a recovery plan that's been outlined and managed to ensure we get back on track. Look, it may sound very simple, but this is the sort of thing that gets lost without an operating system. Next thing we know, the problem snowballs, we're too late to fix it, and another commitment is missed. Great operators keep their promises and have a system to manage them. We will be a great operator, thanks to our lean operating system. We have the right team implementing the lean system on this critical work, and they'll be a valuable resource as we implement lean across the enterprise throughout the year. On that point, in early March, I attended a CPUC workshop on a regionalization filing. I was able to share my thoughts on how PG&E could benefit from implementing a lean operating process on a localized level. We'll leverage the benefit of the lean system and the regionalized teams focused on engaging customers and communities and incorporating their input. We've listened and we've seen that we need to improve our local presence and performance, and we are going to do just that. As we implement the lean operating system, we'll continue to uncover opportunities to improve and take actions to close the gap. In addition to getting our senior leadership team in place, establishing our lean operating system and ensuring a hometown experience, we're able to begin measuring our performance to the Triple Bottom Line of people, planet, and California's prosperity. For PG&E and for California, serving our planet means continuing our leadership role delivering clean energy to our customers. In 2020, 88% of our bundled sales were from greenhouse gas-free sources of energy, more than twice the average across U.S. utilities. We're not resting there, and we're working to bring on over 900 megawatts of additional battery storage by this August, assuring that we have both adequate supply and cleaner resources. I'm particularly excited about these storage opportunities. In fact, earlier this month, I visited the Moss Landing project, where we have one of the largest utility-owned storage facilities in the world, and a great example of a brownfield conversion from fossil fuels to batteries, leveraging the existing transmission resources. We'll continue to evaluate opportunities to add battery storage across our territories, including opportunities in high fire threat areas. Another major initiative is, in fact, our microgrid program. There are many locations across our high fire threat service area, where microgrids make a lot of sense. One example is in Mariposa County, where we had five customers that lost power in 2019 when the line serving them was destroyed. There, we're deploying a utility-owned hybrid renewable stand-alone power system to energize these isolated customers. This option is designed to reliably repower the customers without the need to rebuild the overhead lines. The remote grid offers an alternative at a lower lifetime cost and importantly, at a lower risk of future fire. As you can see, we've got a lot going on here at PG&E. The company has embraced the new vision. The senior leadership team is focused on achieving what all 25,000 PG&E employees and all of our other stakeholders in California want, a company that delivers clean, affordable, reliable energy safely. We'll meet that objective through a relentless focus on people, planet, and prosperity, underpinned by performance. With that, I'll turn it over to Chris.
Chris Foster, CFO
Thank you, Patti. As Patti mentioned earlier, we've started the year focused on execution against the goals we set forth in 2021, including on financial and regulatory matters. I plan to cover our Q1 results and then cover regulatory updates. But just to provide a few highlights up front: first, we're on track for our year-end earnings per share guidance. We're maintaining our 2021 equity guidance range. We've obtained our wildfire liability insurance coverage early this year, totaling $900 million. And we continue to gain financial clarity through progress on our key regulatory cases. As I mentioned, we're on track for the 2021 non-GAAP core earnings per share range we set out at $0.95 to $1.05. You can see here on Slide 8, our results for the first quarter. Non-GAAP core earnings for the quarter came in at $487 million or $0.23. We recorded GAAP earnings of $120 million or $0.06, including non-core items, also shown here. Moving to Slide 9. This shows the quarter-over-quarter comparison for non-GAAP core earnings of $0.23 per share for Q1 2021 versus the $0.89 per share for Q1 2020 or $0.27 per share after adjusting for the increase in shares outstanding. EPS decreased $0.03 related to unrecoverable interest expense, $0.01 from the timing of nuclear refueling outages, $0.01 from the timing of taxes that will net to zero over the year, $0.01 from wildfire mitigation costs above authorized and $0.01 from miscellaneous items. The decreases were partially offset by $0.03 of growth in rate base earnings. Moving to Slide 10. Our guidance for some of our non-core items has changed. I'll start with bankruptcy and legal costs. We've increased the high and low end of our range by $30 million to $1.4 billion to $1.5 billion, reflecting an increase in legal and other fees as we work through the final bankruptcy stages. Now I'll cover the updates on the 2019 to 2020 wildfire-related costs. On 2019 Kincade Fire costs, we have increased the claims accrual by $175 million to a total of $800 million. This reflects increased claims data as well as recent interactions with insurance providers and public entities. Our guidance also now includes $10 million for cleanup and repair costs related to the 2020 Zogg Fire. While not reflected in our guidance because we have sufficient insurance to offset the costs, I'll also note that we increased our accrual for claims related to the Zogg Fire by $25 million to a total of $300 million. This is primarily due to our conversations with public entities and other litigation plaintiffs. Next, the net securitization inception impact has been updated. We expect, assuming the language of both components of the proceeding holds, to record an approximately $150 million pickup for the year following a final non-appealable decision and anticipate that the timing of the charge we previously guided to will largely coincide with the sale of shares by the fire victims trust over future periods. Last year, the prior period net regulatory recoveries item has decreased $80 million to a $60 million pickup for the year. This reflects the impact of a FERC order denying our request for rehearing on TO18. Continuing the 2021 guidance. On our financing plan, as Patti mentioned, we are maintaining our equity guidance of 0 to $400 million for the year. We're evaluating various options, such as an at-the-market equity program to provide flexibility to issue shares within the range, if needed. We'll also be active in the debt capital markets. As you know, we have two securitization proceedings pending at the CPUC. First is our $7.5 billion rate neutral securitization application. The CPUC issued its decision approving the costs under the stress test methodology on April 23, which justifies the amount we requested and the offsetting impact from the creation of the customer credit trust. We expect the CPUC to vote out the decision on the financing order on May 6, giving us the authority to issue securitization bonds. We plan to move expeditiously to issue the securitized debt once the decisions become final and non-appealable. The timing depends on whether there is a challenge to the decision. And if so, how quickly it is resolved. But we expect to complete this issuance later this year or early 2022. And as a reminder, the proceeds of the securitization will be used to retire $6 billion of utility temporary debt and also allow us to accelerate payments to the Fire Victims Trust. One of our key principles in pursuing the structure is also maintained, which is a transaction structure that is expected to be rate neutral while receiving off-credit treatment for the benefit of the utility and our customers. We also filed a request for our first tranche of wildfire safety and risk reduction securitization at the CPUC, as authorized in AB 1054. Our request totals roughly $1.2 billion and reflects the work we completed in 2020 and forecasted expenditures for 2021. We expect to receive a decision on the financing application in late June. Along with our planned securitization issuances, we'll have additional utility debt issuances over the rest of 2021, including potentially later this quarter. Another key update is our early insurance renewal, which I touched on earlier. This year, we decided to target obtaining insurance coverage well before the start of the traditional wildfire season. In April, we secured approximately $900 million of wildfire insurance for 2021 through 2022. From a regulatory perspective, we remain on track to file our 2023 general rate case by the end of June. Our focused investments to reduce wildfire risk and enhanced public safety will continue to be highlighted in this case. The structure of the filing will be different in two notable ways: first, we'll incorporate both electric distribution and our gas transmission and storage business; and second, the case will cover four years, 2023 through 2026, rather than three years, providing certainty of revenues over a longer horizon. This clarity underpins our longer-term projection where our investment in critical safety and risk reduction efforts across our electric, gas, and generation systems is at the core of 8.5% rate base growth. Our strong rate base growth, coupled with a disciplined approach to deleveraging our balance sheet while managing our equity needs, drives our 10% non-GAAP core earnings CAGR. And with that, I'll turn it over to Patti.
Patti Poppe, CEO
Thank you, Chris. As I said, it is an exciting time here at PG&E. We will meet the challenges that lie ahead, such as ending catastrophic wildfires by demanding excellence of ourselves in our wildfire prevention work, creating a culture of performance by building the lean operating system on a regional basis across the enterprise during 2021, and continuing our focus on delivering clean energy to our customers through the latest technologies in battery storage, electric vehicle infrastructure, and microgrid solutions. Our financial performance is driven by these three focus areas. We can deliver on these objectives and thereby serve our customers and our investors better than ever before. We are on the path to a new era at PG&E, focused on people, planet, and prosperity underpinned by performance. Operator, please open the line for questions.
Operator, Operator
And your first question comes from Julien Dumoulin-Smith with Bank of America.
Julien Dumoulin-Smith, Analyst
Congrats on all the continued progress of your team. Perhaps at the outset, if I can ask, Chris, maybe you mentioned keeping the $0 to $400 million of equity range and looking at the aftermarket, can you talk about some of the updated puts and takes as to how you think about potentially needing to access equity here, if you don't mind?
Chris Foster, CFO
Sure thing. Julien, in short, we kind of have to start with the start, which is the CPUC has not completed yet the final decision on the financing order for our securitization case. So again, we're looking at soon here, that's May 6. Certainly, that's our really the first gating item there. And then beyond that, as we mentioned today, we're certainly still working through some legacy legal items. We did update for both Zogg and Kincade, and we are in some ongoing discussions there as well. So from an approach for this quarter, we wanted to be sure to be appropriately conservative as we work our way through some of those issues.
Julien Dumoulin-Smith, Analyst
Got it. Excellent. And can you just elaborate a little bit more on what the issues you're working through there? And perhaps, if you can elaborate anything at these expected time lines on resolution there as best you see it, I guess, that it's always quite difficult?
Chris Foster, CFO
Sure, Julien, it's hard to be specific, as you can imagine. We did note in our disclosures today that we are in live conversations, is how I would think about it, on both the Kincade Fire and the Zogg Fire, Kincade particularly, with the related to the insurance claims of the subrogated claims as well as public entities. And similarly, on the Zogg Fire with public entities as well as some individual plaintiffs. So obviously, just the complexity of some of the cases, it's hard for me to be specific about timing of resolution, but certainly want to move forward as expeditiously as possible, knowing the impact to victims.
Operator, Operator
And your next question comes from the line of Steve Fleishman with Wolfe Research.
Steve Fleishman, Analyst
Can you hear me?
Patti Poppe, CEO
Yes, we can hear you, Steve.
Steve Fleishman, Analyst
So maybe first, just a high-level question. The stock's been relatively weak, and I think it's now trading at a more than 50% discount to the average utility. And so I guess just to somebody who was an outsider kind of coming in and now spent several months getting very in tune with the company in California and just the regulatory structure environment, et cetera, and then also the wildfire risk, just I'd be curious your thoughts on does it make any sense that PG&E would trade more than 50% below the average utility?
Patti Poppe, CEO
Well, Steve, you can imagine I ask myself that question quite routinely. As I've gotten on the ground here and really gotten on solid footing, there are a couple of things that I think about and I observe, and actually makes me very hopeful. One is the regulatory construct in California was a pleasant surprise. I long heard about the regulatory construct; it's actually very good. We've got multiyear general rate cases, pass-through costs for commodity procurement, decoupling, and separate cost of capital proceedings. It's a good construct that provides for reliable outcomes. The State of California recognizes the risk of wildfire. The state and we at PG&E, as well as all of the investor-owned utilities, have learned a lot about wildfire mitigation. I have a saying associated with our lean operating system that says you can't fix what you don't know about. And we know a lot about what we're doing now under these conditions. The state has stepped up, the commitment to increase the equipment, fire and forest health, fire prevention, and fire crews. I think the CAL FIRE and all of our firefighters across the state have demonstrated their incredible capacity and their improvement and everything they've done to fight wildfires. So it really comes down to the question I ask myself about us here at PG&E: can we, in fact, perform? And I wouldn't be here, Steve, if I didn't believe that we can. And this lean operating system that we talk about all the time is because we talk about it all the time; it is how we will create this culture of performance. It is what we've deployed against our wildfire mitigation plan for this year. We're seeing results of it right now as we speak. And so I just have to tell you, I think that a lot of companies have a lot of different kinds of risks, and you can't fix what you don't know about. We know about this risk. We've gotten incredibly sophisticated about dealing with this risk. And we've got the team for the time to deliver on this risk. And so I'm a believer. And I guess I'd just say that. If I believe, I think there's a lot of reasons for other people to believe in PG&E.
Steve Fleishman, Analyst
Great. That's helpful. Just on your comment on the Sonoma District Attorney filing on Kincade Fire, just have they given you any rationale for the criminal charges there? What is the basis?
Patti Poppe, CEO
They have clearly laid out what the charges are, and the rationale behind them is somewhat implied. I want to emphasize that the Sonoma County District Attorney is elected and has a responsibility to her constituents. We do not agree with these charges as we see no criminal basis for them, and we intend to contest them. Ultimately, our focus remains the same: for every challenge I confront, every insight I gain, and every opportunity I identify, the answer is consistent. We aim to enhance our performance, execute our wildfire mitigation plan, and prevent future disasters. Our commitment is to be a reliable company that prevents incidents. That is the sole focus for my team and me; we are dedicated to fostering a culture of performance and ensuring safety in California while preventing catastrophic wildfires stemming from our equipment.
Steve Fleishman, Analyst
Okay, great. And one last question. Just any update on the status of this grantor trust election and then just any update on intentions of the Fire Victims Trust with their stake in the company?
Chris Foster, CFO
Sure. Steve, it's Chris. I'll take that. I think we're on a good path is the short answer. At this stage, we do have a positive private letter ruling from the IRS. We have good alignment in terms of shared benefits for both the Fire Victims Trust and the company toward completing this work. Just yesterday, we received approval in the bankruptcy court for the motion regarding our share exchange, which is a good data point. Moving forward, there are a couple of considerations to keep in mind. The first is the approval needed from a California entity, which I believe is scheduled for the third week of May. We will also be working on finalizing some of the definitive documents we're pursuing. Overall, I think we continue to be on a good path, and we're looking at that May timeframe to ideally be in a position to elect.
Steve Fleishman, Analyst
Okay. And just to clarify that, the exchange of stock with you does not require the trust to sell stock to the market; that's just an exchange with you?
Chris Foster, CFO
Thank you for your question as there seems to be some confusion about it. That is correct. You can think of it as an instantaneous exchange with the company. It does not actually create a mandate to sell.
Operator, Operator
And your next question comes from the line of Ryan Levine with Citi.
Ryan Levine, Analyst
I guess I wanted to start off around the increased drought risk since the Wildfire Mitigation Plan was submitted. In light of some of the recent developments, are there any opportunities to amend or derisk the wildfire risk in the upcoming season in light of some of the changing weather conditions within your service territory?
Patti Poppe, CEO
One of the things we're doing is drilling earlier. We have an excellent partnership with our community safety organizations and firefighters, and we're conducting those drills in preparation for the wildfire season earlier due to the drought conditions. We will be drilling in the south and central regions in May, and in the north in July. This is an important part of getting ready and ensuring we are aligned and coordinated. During an emergency response, that coordination is essential for achieving better outcomes. That's one of the initiatives we have in place. More importantly, we're executing our plan, much of which is set to be implemented early by September 1. Some of our work will be complete by then, but we are actively working every single day. We are derisking the system daily with our hardening efforts and equipment upgrades, and we are fully focused on these initiatives.
Ryan Levine, Analyst
Okay. And then in terms of the $900 million wildfire insurance cost that I think Chris had highlighted that you had purchased, can you provide a little color as to why you made that election earlier this year? And what the pricing and terms were to the extent you're able to comment on that insurance purchase?
Chris Foster, CFO
Sure thing. Ryan, I would consider that we were looking at the change in our policy timing. In prior years, our policy period ran from August 1 to July 31. By moving it earlier in the year, we create some distance from the beginning of the traditional fire season. As a result of this change, we see an increase in insurance coverage from about $868 million to $900 million for this year. Additionally, the improvements in policy elements have provided us with greater coverage, and we achieved this increase at a lower cost compared to last year's coverage. Our team worked hard to ensure we're well-prepared for this fire season, leading us to this $900 million figure for the year.
Ryan Levine, Analyst
Okay, appreciate it. And what about in terms of pricing on the $900 million?
Chris Foster, CFO
Sure, we're analyzing the pricing structure since it involves multiple policy segments. One segment is a multiyear policy amounting to about $600 million that spans several years. Additionally, we have a specific breakdown for the extra amount that brings our total to $900 million for this year. If you're interested, we can provide more details about the specific segments. We've also included additional information in our 10-Q today that offers more insight than we have in the past to assist you.
Ryan Levine, Analyst
Okay, great. And then maybe just one clarifying question around the equity issuance plan. Is there any changes in working capital that we should keep in mind, considering the pace of COVID or our exit from it, aside from the highlighted securitization proceedings and the legacy claims?
Chris Foster, CFO
I appreciate that question. As I consider other factors more broadly regarding cash, there are no significant working capital changes. A notable effort we are currently undertaking is the sale of our San Francisco headquarters, which will impact cash both in terms of timing and amount. The team is now working with the broker, and we will be moving forward with this process. At this point, we are sorting through the details and evaluating bids, but I am excited to advance this initiative.
Operator, Operator
And your next question comes from the line of Jonathan Arnold with Vertical Research.
Jonathan Arnold, Analyst
Just one quick one for Chris first, and I have a broader question. Chris, could you just explain the recent change in the timing of when you would recognize the loss that you had previously expected to be more upfront? I thought that you were expecting the grantor trust election when you updated last quarter. So I'm just trying to figure out what changed in the timing there?
Chris Foster, CFO
Absolutely. Jonathan, to start off, I want to acknowledge the progress the CPUC has made on our securitization cases. The decision clearly recognizes the benefits for customers and the Fire Victims Trust, aligning with our goals for both SB 901 and AB 1054 in terms of enhancing the company’s business risk profile. It's important to keep this in mind. As we reassessed and updated our accounting, we aimed to provide you with the clearest picture of the net impacts from both the grantor trust treatment and the securitization outcome. We expect to record a $150 million pickup for the year following a final non-appealable decision. Additionally, we anticipate that the timing of the shareholder-funded charge we previously communicated will largely coincide with the sale of shares by the Fire Victims Trust over future periods. This is primarily about a change in the timing of the expense, which we are reflecting and updating today in a positive manner.
Jonathan Arnold, Analyst
Just the timing of how you're going to recognize it as opposed to when the cash flows may or may not occur?
Chris Foster, CFO
That's correct. That's right.
Jonathan Arnold, Analyst
I'll provide my feedback on that. You mentioned you will be holding an Analyst Day in August. Can you give us an idea of what you aim to achieve during that event and what we should expect?
Patti Poppe, CEO
We are eager to welcome everyone to California safely, depending on the COVID situation. We want you to save the date and start making your plans. Our goal is to introduce you to our team, showcase our wildfire mitigation plans in action, and let you connect with our talented technical staff, who inspire confidence in me and will likely do the same for you. Additionally, we aim to discuss our strong commitment to a performance-driven culture and our clean energy strategy. This is an exciting aspect of PG&E's narrative that deserves more attention. We are enthusiastic about sharing it and helping people see the promising future PG&E has in serving California. There is no replacement for in-person interactions, and I look forward to seeing you soon.
Operator, Operator
Your next question comes from the line of Stephen Byrd with Morgan Stanley.
Stephen Byrd, Analyst
A lot has been covered. I wanted to just talk about the CPUC and their assessment of the, I guess, the long-term future of natural gas. And just curious sort of your thoughts and dialogue with the CPUC, anything you would highlight there?
Patti Poppe, CEO
I understand that this is a topic of concern for many. In the coming decade or so, natural gas will continue to serve as an important transitional fuel in clean energy scenarios. Our customers still desire natural gas, and we need to focus on minimizing methane emissions through responsible practices. Upgrading services or changing mains helps reduce our fugitive emissions, which we are proud of. However, we recognize there is more to explore regarding the long-term role of natural gas in California. We are currently engaged in strategic planning to address this and will share more information publicly when the time is appropriate.
Operator, Operator
And your next question comes from the line of Michael Lapides with Goldman Sachs.
Michael Lapides, Analyst
I think I have probably one for Patti and one or two for Chris. Patti, when we look at your CapEx spend, so if I come back and look at your slides that you have, and your very progressive goal to eliminate all utility-caused wildfires, if I look at the gray bars on Slide 11, are those funds that you need to spend to be able to hit those goals? And were those funds, meaning the embedded in the gray bar, things you wouldn't actually spend if you didn't get state regulatory approval, but it would put that goal of eliminating utility-caused wildfires at risk?
Patti Poppe, CEO
Well, I'd say there are two things that help us mitigate utility-caused ignition risk. One is our hardening of our system. And so obviously, the investments that we're making there are very important, and we have a widely alignment with the CPUC and the Wildfire Safety Division. In fact, the Safety Division Director spent three days with us just a week ago, actually out in the field, observing our mitigation efforts and what we're doing to harden the system and the enhanced vegetation management efforts that we're taking. And so I would say we broadly have alignment on investments necessary to do our work. But we also mitigate risk and prevent ignition and specifically on catastrophic wildfire through our PSPS program. And so that's another important complement too. We try and represent this notion that, in the near term, PSPS is our backstop, and it needs to be an important measure that we take to protect people's safety and prevent fires of consequence. But over time, our hardening investments, as you've described, will help to mitigate the actual source of ignition in the first place. So I'm getting pretty excited about what we're learning about how to make that happen through new technologies as well as just some of the fundamentals of undergrounding the right portions of the grid, doing these remote grids where necessary, conductor hardening as well as all the other equipment that we're learning about and utilizing. Some of it quite traditional, some of it new and exciting. So that capital plan really does a major part of what we need to do to mitigate wildfire hazards.
Michael Lapides, Analyst
But if you didn't get approval for those gray bars in this upcoming case or in some of the memo accounts, would you spend it anyway because it is the thing that needs to happen on the system to eliminate wildfire risk?
Chris Foster, CFO
Michael, it's Chris. I'd like to expand on that. The advantage we have in the state is that we now have annually filed wildfire mitigation plans. This provides excellent transparency into how we're adjusting our plans year over year and how our risk model helps us evolve our work. It also helps align with the points that Patti mentioned. We're making an effort to offer this level of transparency, as illustrated by the gray bars. We fully expect to recover costs associated with the work that directly aligns with what we've filed in our plan. There is a slight regulatory delay in cost recovery, but the positive aspect is that it does not face the same regulatory lag as general rate case requests. Each year, we present a wildfire mitigation plan and commit to the necessary work. As long as we follow through, we're confident in recovering the costs shown in the gray bars. Additionally, we are planning to file our 2023 general rate case by the end of June, which will provide a chance to better outline our multiyear investment priorities. Overall, this is a transparent process with the CPUC, and our focus is on executing the work we've committed to.
Michael Lapides, Analyst
Right. One follow-up, Chris, in your prepared remarks about the securitization and the timing, and you made the comment of end of year or beginning of '22 for the actual issuance. But then you followed that with a brief remark about assuming all appeals or litigation at risk. If litigation delayed the issuance, how does that impact, a couple of things: how does that impact when you make your $1 billion payment to the wildfire victims trust fund? And how does that impact your earnings guidance, which assumes you'd be paying down a lot of debt that you're actually not recovering in the customer bill?
Chris Foster, CFO
Sure. Again, it's a bit of a scenario, but I hear where it's coming from. I think ultimately, what we're trying to do our best to do is provide the understanding that in the situation where there is an application for rehearing that would move forward or something of that sort, we still envision a situation where we're prepared to execute this year. I did mention 2022 because the other factor that's in there, Michael, is just the market. And so at this size of the offering, we want to make sure to give ourselves the flexibility. On the $7.5 billion, if we need to evaluate doing multiple tranches, there's a scenario where a portion of it could move into 2022. So really, that's just our way of expressing. In one sense, if there's a delay, it would delay the final payment to the Fire Victims Trust. It could delay the initial contribution. But again, still looking at a situation where we'll execute this year.
Operator, Operator
Our next question comes from the line of Paul Fremont with Mizuho.
Paul Fremont, Analyst
I guess, if you fight the criminal charges in the courts, are we talking about months? Are we talking about years before you would potentially get a resolution out of the court on those matters?
Patti Poppe, CEO
First of all, it's hard to say. And there's a lot of contributing factors to that. It could be months; it could also be up to potentially two years. So I would just say there's a range and a lot of factors that will go into that.
Paul Fremont, Analyst
And then I mean, is it fair to say that if there are criminal charges that would potentially come out of Zogg that we wouldn't know either way until roughly a year from now, just given the timeline of when they acted on Kincade?
Patti Poppe, CEO
Yes. I would say those things are linked. If there are criminal charges and any of them are upheld, we wouldn't know the outcome until that occurs. However, I want to emphasize that we disagree with these charges and are committed to fighting them because we firmly do not agree. That is our main focus at the moment.
Paul Fremont, Analyst
I'm just trying to understand whether the criminal charges would undermine your ability to recover under 1054, particularly if the charges were upheld.
Chris Foster, CFO
Paul, I want to clarify that AB 1054 does not address criminality in the manner you're suggesting. Your mention of the timeframe related to any potential criminal charges associated with the Zogg Fire is correct; it follows a similar timeline. Therefore, it is valid to consider the timing in that context, but AB 1054 does not view criminality negatively in that regard.
Patti Poppe, CEO
And Paul, just to wrap this up. To be clear, we cannot speculate about all these conditions, but the key point is that we disagree. We disagree with the charges, and we are going to contest them.
Paul Fremont, Analyst
Great. And maybe the last question for me on Zogg. I guess I've seen different accounts with respect to whether the tree that was involved was marked for removal or not? Is there any further clarification that you might be able to give on that tree?
Patti Poppe, CEO
Yes. There's no new information to share on that, Paul.
Operator, Operator
That concludes all questions for today. I'd like to turn the call back over to Patti Poppe for closing remarks.
Patti Poppe, CEO
Thank you, April. Well, thanks, everyone, for joining us today. Our future becomes significantly derisked as we deliver day in and day out. This is a long game, and we're in it to win it by serving our customers and our investors. We really do look forward to having you safely with us in California on August 9, for our Investor Day at our Wildfire Command Center. I want you to see the team that is in action and learn what I know. We are entering a new era at PG&E, grounded in our Triple Bottom Line that is underpinned by our performance. We will see you soon. And in the meantime, stay safe and be well.
Operator, Operator
That concludes today's conference call. Thank you for your participation. You may now disconnect.