PG&E Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	PG&E Corp provides highly detailed and candid disclosure of its climate-related policy engagement. The company names a wide array of specific measures it has lobbied on, including the federal Infrastructure Investment and Jobs Act, California’s SB 1020 Clean Energy, Jobs and Affordability Act, CARB’s Advanced Clean Fleets regulation, Net Energy Metering reform, a "well-designed federal price on carbon," the Inflation Reduction Act, and numerous other state and federal bills, regulations and rulemakings. PG&E also explains how it seeks to influence these policies and whom it targets. It describes direct actions such as “engag[ing] key legislators and committee analysts to discuss PG&E’s position on the bill,” submitting letters to the California Energy Commission, putting forward proposals at the California Public Utilities Commission, participating in CARB technical workshops, and responding to U.S. Department of Energy requests for information, as well as indirect engagement “through allied organizations, including the CEO Climate Dialogue” and industry trade bodies. Each disclosure identifies the relevant policymaking body—CARB, CPUC, CEC, Congress, DOE or other federal agencies—demonstrating clear line-of-sight from activity to decision-maker. Finally, PG&E sets out the concrete results it seeks. It supports credits to keep Diablo Canyon operating, an “orderly and systematic transition … away from the use of SF6,” creation of a carbon-neutral-by-2040 scenario in CARB’s Scoping Plan, reforms to Net Energy Metering that “ensure customer affordability,” expansion of federal EV tax credits and charging-infrastructure grants, incentives for building electrification, and a national Clean Energy Standard that balances reliability and cost. Where it withholds support, such as on carbon-sequestration legislation until safety provisions are added, it explains the rationale. The combination of specific policy references, clearly described lobbying channels and targets, and detailed, measurable policy aims reflects a comprehensive level of transparency around the company’s climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	PG&E Corp has established a defined governance process that ties its lobbying to its climate strategy through its longstanding Climate Change Policy Principles, which “guide our activities and ensure consistency with PG&E’s climate change strategy,” and is executed by a “cross-functional team comprised of representatives from across the company” that meets regularly with executives to “seek approval on policy positions.” Oversight is provided by the “Sustainability and Governance Committee of the PG&E Corporation Board of Directors,” while the “Executive Vice President of Corporate Affairs and Chief Sustainability Officer” leads development and implementation of public policy. PG&E further notes that its “public policy work, including engagement with elected officials and policy makers, is done in collaboration with trade organizations” such as the Natural Resources Defense Council, yet the company does not disclose a formal process to review or realign the positions of those associations against its climate commitments, nor does it publish a dedicated lobbying audit or report assessing alignment between its advocacy and its stated goals.	2