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Operator
Ladies and gentlemen, thank you for standing by, and welcome to the PG&E Corporation Third Quarter 2020 Earnings Release Conference Call. (Operator Instructions) Please be advised that today's conference is being recorded. (Operator Instructions)
I would now like to hand the conference over to your speaker today, Matt Fallon, Senior Director, Investor Relations. Thank you. Please go ahead.
Matt Fallon;Senior Director, Investor Relations
Thank you, Rob, and thanks to those of you on the phone for attending. Joining us this morning are Bill Smith, our Interim Chief Executive Officer; and Chris Foster, Vice President and Interim Chief Financial Officer. Also joining us today are John Simon, Executive Vice President, General Counsel and Chief Ethics and Compliance Officer; Michael Lewis, Interim President of Pacific Gas and Electric Company; and Robert Kenny, Vice President, Regulatory and External Affairs.
I want to remind you that on our discussion today, we'll 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 most important factors that could affect the company's actual financial results are described on the second page of today's third quarter earnings call presentation.
The presentation also includes a reconciliation between non-GAAP and GAAP measures and 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 that was filed with the SEC earlier today and the discussion of risk factors that appears there in our Q2 10-Q and in the 2019 annual report on Form 10-K.
With that, I'll turn it over to Bill.
William L. Smith - Director
Thanks, Matt, and good morning, everyone. Thank you for joining us today. Before I cover the priorities for the quarter, I want to express our sympathy for all of those impacted by the devastating wildfires we've experienced in California this year. It's been a historic and very challenging wildfire season for our customers. We've seen over 4 million acres burned in California, with nearly 3 million acres burned in our service area. We thank the governor's office, CAL FIRE, California Office of Emergency Services and all the first responders for their tireless efforts in keeping our communities safe.
We continue to focus on executing a series of important changes at PG&E. These changes will help us live up to the commitments made as a part of our Chapter 11 emergency plan, including our efforts to improve our operations and safety outcomes, reduce risk and enhance our customer focus. This morning, I'll touch on 3 key areas of focus for PG&E. First, improvements to our Wildfire Mitigation Plan; second, our operational updates; and third, our executive leadership recruitment progress. Chris will then cover our financial updates in key regulatory cases.
Looking at our Wildfire Mitigation Plan, our highest priorities remain mitigating ignition risk, enhancing our situational awareness and implementing Public Safety Power Shutoff, or PSPS events. We will initiate these events when absolutely necessary to protect public safety.
As you can see on Slide 4, we continue to be on track or ahead of our 2020 targets for system hardening, enhanced vegetation management and installation of weather stations and high-definition cameras. Our efforts over the last quarter have our weather station and camera installations back on track.
We will respond to -- to Judge Alsup's request for information in the monitors report of PG&E's enhanced vegetation management inspections next week. We share the monitor in the court's goals in ensuring we operate in a safe and reliable grid. While we acknowledge there are some areas where our comprehensive Wildfire Mitigation Plan that we stood up in 2019 could improve, we do see some of the results somewhat differently than the letter provided by the monitor. We are unable to comment further ahead of our response, which will be filed on November 3.
There is one aspect of the wildfire mitigation program that I'll give a detailed update on, and that's our Public Safety Power Shutoff or PSPS program. We've done a lot since 2019 to increase cooperation with local authorities by hiring additional talent with emergency planning expertise. We also prioritize better communications with our customers this wildfire season.
The technology improvements that will help us achieve our program goals are highlighted on Slide 5. As we have in prior years, we'll continually evaluate conditions that include wind speed, humidity levels and fuels moisture, among other factors. When conditions warrant, we will implement power shutoffs as a last resort to keep our customers and communities safe.
We have taken steps to minimize the impact of these events on our customers, and we've executed 5 events so far this year. We have made our events smarter through leveraging technology, smaller by implementing sectionalization devices as well as temporary generation, and shorter by increasing our post-event inspection capabilities. We have engaged with our communities and our customers to implement changes that incorporate their feedback. While we have improved in 2020 versus 2019 and making these events less disruptive, we continue to learn from each event.
To make our program smarter, we collect fuels moisture data and incorporate it into our fire spread modeling. This data is an important indicator, along with wind speeds in assessing our conditions in real time. We utilize the fuels data along with forecasting work we do in collaboration with a national weather service to determine where we need to implement a PSPS event.
Our next priority to improve the program is to make the impacted customer footprint smaller. We have prepositioned temporary generation in regions that are prone to shutoff events. We installed 600 sectionalization devices, which were in place by the end of August. In addition, we've added an islanding configuration at the Humboldt Bay and Caribou generating stations, which allow almost 70,000 customers to stay online. Those customers would have been shutoff in 2019. This is one example of how we've implemented lessons learned from previous wildfire seasons.
These actions allowed us to meet our goal of a 1/3 reduction in customers impacted in our first events. In order to make outages shorter, we've increased our aerial patrol abilities through additional helicopters and fixed-wing aircraft. We now have access to more than 60 helicopters to help us meet our goal of a 50% faster restoration time versus 2019.
I'd like to touch on a couple of other areas of PSPS implementation, where we've increased our focus in 2020. This includes our coordination with county and city emergency managers and our outreach to customers. In December, we started holding town hall listening sessions with city managers, first responders and residents. At these sessions, PG&E senior leaders listened to the local stakeholders and started working on plans to improve coordination for the 2020 PSPS events.
Our team then held subsequent discussions where we walked through local plans for these events based on the information we learned in the listening sessions. As an example of change made resulting from these listening sessions, we increased the local presence of PG&E personnel to coordinate with emergency managers. These important employees serve as a single point of contact for individual counties and cities during a power shutoff event.
On the customer side, we've also made significant changes in response to lessons learned in 2019. We conducted webinars focused on wildfire safety initiatives in the counties we serve. We ask questions and receive valuable feedback, which we've used to address the concerns and needs of our customers on a county-by-county basis.
We've worked hard on 3 specific areas related to customer engagement during PSPS events. The first is our notification system, the second is our website and the third is customer resources provided by PG&E.
With regard to our notification system, we work to notify customers with an initial watch notification message as early as 48 hours prior to event. The PSPS watch will be upgraded to a warning when forecasted conditions show that a safety shutoff will be necessary. Warning notifications are sent approximately 4 to 12 hours in advance of an event. These messages also include an expected restoration time. Outage and restoration information is updated throughout the event. We improved our messaging in direct response to customer feedback from last year.
Second, on our website improvements, we have moved pge.com from our data centers to the cloud, where we tested the site to levels well beyond the demand we saw during our peak usage in 2019. Our enhanced web capability allows for customers to look up shutoff times and estimated restoration times by address. This information is available as early as 2 days before an event occurs.
Also, we increased the number of our community resource centers during PSPS events. In our first event this year, we had 50 community resource centers available for an outage impacting 172,000 customers. By comparison, in 2019, we had 80 centers for 1 million customers impacted. These centers provide a place for customers to go during power shutoffs and are equipped with charging stations, bottled water and other necessities. All of these locations comply with COVID safety protocols.
We expect to have incremental opportunities to leverage technology to improve our Wildfire Mitigation Plans and our PSPS implementation. We continue to incorporate feedback from our community leaders and our customers to improve these events.
With respect to updates and next steps on wildfire filings, as we indicated before, we anticipate a decision on our safety certification request at the CPUC by the end of this month. We believe we provided all the necessary information, and we hope to see that outcome any day now. As a reminder, the prior certification we received last year remains in place.
Looking forward, we will take the learnings from our Wildfire Mitigation Plans as well as our PSPS adjustments and will reflect them in our 2021 Wildfire Mitigation Plan filing. Last week, the Wildfire Safety Division gave all 3 IOUs a February deadline for that submission.
One additional note on operations, we notified -- we were notified earlier in the month that CAL FIRE has taken possession of PG&E equipment as a part of their ongoing investigation into the cause of the Zogg Fire, which was west of Reading, California. Given the early stage of the investigation and the fact that we haven't had an opportunity to review the assets retained by CAL FIRE, there is limited additional information to provide today. We are fully cooperating with CAL FIRE in its investigation and will provide more information on the Zogg Fire at the appropriate time.
In addition, on Monday, we filed a response to Judge Alsup's request for information on the Zogg Fire. We will not comment any further as to we do not want to get ahead of the CAL FIRE investigation.
While our electric operations are certainly an area of focus given our effort to mitigate wildfire risk, I also want to highlight the continued good work done by our gas operations team.
One of the major initiatives to make our gas system safer is to enable in-line inspections. This method is preferable to traditional hydrostatic testing in a couple of ways. It eliminates the need for a line to be taken out of service for testing and it's safer than hydrostatic testing, which can compromise the strength of the pipe. In terms of day-to-day operations, our gas odor average response times and our third-party dig-in rates are at the upper end of industry standards. These are 2 areas of focus to ensure we provide safe and reliable gas delivery.
I want to mention 2 facilities that we opened in 2017 that have helped us improve our gas operations. These centers will open in direct response to a comprehensive evaluation of our operations. First, in 2017, we opened the Center for Gas Safety, which has expansive lab space that allows us to test new technologies. Second, we opened our Gas Safety Academy. Here, we offer gas operations team, a training space that simulates various gas emergencies we encounter in our territory. These 2 centers were open to ensure that we have given our operations team the necessary technology and training facilities to drive continuous improvement. We will look to the practices we have implemented in our gas business and our wildfire mitigation efforts to continue to inform our path forward. While we accomplished a lot in increasing safety and reducing risk, we continue to work hard to improve.
The last thing I'd like to cover is the progress we're making on open executive leadership roles. We remain on track to name a new CEO as well as a President of Utility by the end of the year. We have also kicked off a national search for a CFO. All 3 of these key senior leadership searches are being supported by the same firm that will help with the alignment of abilities and backgrounds. We are fortunate to have Chris Foster taking the lead as Interim CFO. Chris is leading a very strong finance department while we conduct our search for a permanent CFO.
These leaders will build off of few recent hires that are very exciting. Those include Francisco Benavides, our Chief Safety Officer; Sumeet Singh, our Chief Risk Officer; and Ajay Waghray is our Chief Information Officer. These 3 recent additions to the PG&E team reflect our commitment to change. We will continue to operate with a focus on safety and risk while continuously looking for new ways to implement technology to increase efficiency.
To build on that a bit, I'd like to share a recent initiative that we kicked off. We are taking a focused look at our operations. We will look to operate more efficiently and improve our relationship with our customers by creating an enterprised approach to asset management, adopting consistent work management practices and implementing tools to measure, track and monitor our customer experience. We'll have more to share on this initiative as we move into 2021.
In closing, I want to express my appreciation for all PG&E frontline employees. Our employees are navigating a difficult operating environment, and they continue to execute on safety, risk reduction and reliability programs across electric and gas systems.
With that, I'll turn it over to Chris to cover our financials and some key regulatory cases. Chris?
Christopher A. Foster - VP & Interim CFO
Thank you, Bill, and good morning, everyone. I plan on covering 4 items, which are highlighted as the key takeaways on Slide 3.
First, we are on track in reaffirming the 5-year earnings guidance we set last quarter. This is reflective of the consistent growth we anticipate over the coming years. Second, I will provide an update on our insurance coverage, the impact of COVID in our financing need. Third, I'll highlight meaningful progress on our regulatory cases that provide additional revenue clarity. Lastly, I'll briefly cover the third quarter results.
Starting with our earnings guidance elements. They are highlighted on Slide 10. We have updated our GAAP earnings guidance range slightly for 2020 to reflect the loss between $1 and $1.06 per share. We are reaffirming non-GAAP core earnings per share guidance as well as our earnings factors for both 2020 and 2021. Specifically, in 2020, we are guiding to non-GAAP core earnings of $2 billion for the year, or approximately $1.60 to $1.63 per share. This is based on weighted average shares of roughly $1.25 billion in 2020.
The drivers of variance from earning our authorized return remained unchanged. Also noted here are the key assumptions underlying 2020 guidance. This includes receiving a final decision in the 2020 General Rate Case in the fourth quarter. Our guidance is also consistent with the TO20 formula rate settlement and assumes FERC's approval of our separate AFUDC waver request, reflected in this settlement in the fourth quarter. I'll come back to these regulatory items to provide more color.
Moving to noncore earnings guidance, which is broken out on the same slide. We've made a couple of adjustments to these items. Our range for bankruptcy and legal costs increased $30 million to the range of $2.66 billion to $2.7 billion. Increase to the range reflects a final adjustment required to the fair value of the equity backstop fee based on the share price at the beginning of July.
Additionally, for investigation remedies and cost recovery, we have lowered the forecasted spend from $300 million to $230 million for the year. Roughly $30 million of this decrease is permanent, and we will apply it towards the Wildfire OII spend requirement. The remaining difference is a timing item that will impact 2021 noncore spend.
We have increased the guidance for 2019 Kincade Fire-related costs by $20 million to approximately $170 million for the year. During the third quarter, we received information from potential claimants, including insurance subrogation claims that led to an increase in our accrual from $600 million to $625 million pretax.
As it relates to the Kincade Fire, we continue to not have access to CAL FIRE's investigator report or the evidence they have collected.
We've also included a pickup of $50 million for the category prior period net regulatory recoveries. This category includes 3 items. First, we've included revenues related to the 2011 GT&S capital audit, consistent with previous guidance. This quarter, we've also added a pickup for the 2019 impact of our modified AFUDC filing. Partially offsetting the first 2 items are prior year revenue reductions that are associated with FERC's recent order on to TO18 and the TO20 settlement now pending with FERC.
Our full year guidance for the amortization of the Wildfire Fund contribution remains the same.
Moving to 2021 guidance on Slide 11. We continue to see non-GAAP core earnings of $2.1 billion to $2.3 billion for the year or approximately $0.95 to $1.05 per share. This non-GAAP core earnings target is $275 million to $425 million below our authorized levels. This range is mostly comprised of interest expense of $275 million to $325 million. Additionally, net below the line and spend above authorized will taper off as we carry out additional efficiency measures. This includes revisiting contracted work, such as contracts for wildfire mitigation and brings us to our range of $0 to $100 million there.
Next, I'll cover updates on our noncore asset sales, insurance coverage and the impact of COVID-19 and the effect of these items on our financing needs. As we mentioned in our second quarter call, we are considering selling a set of small noncore assets. We remain early in the process there, but we have made some progress on that front. If successful in 2021, the impacts from such a transaction could reduce the high end of our $450 million to $750 million forecasted equity range for the year. We've also filed an application with the CPUC for approval to sell our San Francisco office complex, fulfilling the commitment we set out in our plan of reorganization. Based on an illustrative sale price of $1 billion shown in our application, a benefit of $600 million would flow back to customers. We are looking at 2021 for the likely timing of the sale.
Moving to our wildfire insurance. We have made progress in accessing over $100 million of additional coverage since the second quarter. That puts the wildfire liability insurance component of our overall insurance portfolio at up to $868 million in coverage for the period.
With regard to the impact of COVID-19, we continue to experience higher uncollectible costs during the year as well as incremental operating costs. Roughly $90 million has been recorded in memorandum accounts created to track COVID-related costs for collection in future periods.
When combining the impact of higher insurance costs, the timing of the general building office sale, and the timing of recovery for COVID-19, we foresee a short-term cash need in the fourth quarter that we anticipate will be met with short debt. We do not see these items changing our equity needs.
I will now shift to covering a few significant updates on the regulatory front. We've made progress in a few areas that keep us on the path to achieving the guidance range that we set out last quarter. I'll start with FERC. 2 weeks ago, we filed a settlement in the transmission owner 2020 rate case that is subject to approval by FERC. We are pleased with the outcome and the support of the broad set of settling parties. There are a few elements to the settlement that I'll highlight. First, we established an all-in return on equity of 10.45% and a capital structure that is 49.75% equity. These factors remain in place through 2023. This settlement establishes our first formula rate case that brings clarity with the annual expense to our process. And additionally, the settlement outlines a modified AFUDC waiver filing with FERC that, if approved, will allow us to apply a higher equity ratio on AFUDC back to May of 2019. That is being reviewed by FERC staff on a separate track and we assume completion of that review by the end of Q4.
I'll now shift to the cases of the CPUC. Last week, we received a proposed decision on our 2020 General Rate Case. The outcome is largely similar to the multiparty settlement we reached last December and does not impact our 2020 or 2021 earnings guidance. The total $9.1 billion revenue requirement was unchanged. The proposed decision does include changes to the cost recovery process for liability insurance, vegetation management and wildfire mitigation capital and expense. Specifically, the proposed decision would require us to file separate applications for the recovery of costs above 130% of the authorized amount. It also proposed reduction to the authorized wildfire mitigation capital costs. These are considered AB 1054-related capital spend at the magnitude of roughly $900 million over 2 years. These amounts were already excluded from our rate base forecast, so we do not anticipate a change in our rate base projection. The timing of this proposed decision should keep us on track for a final decision by the end of the year, which aligns well with the previous statutory deadline of December 13 set forth by the CPUC in June.
We have also sought recovery for roughly $1.3 billion of 2017 through 2019 costs through our recent wildfire mitigation and catastrophic events or WMCE filing at the CPUC. Related to these costs, we received a decision in our CEMA case last week that allows us to recover roughly $450 million beginning in December. Now the wildfire mitigation catastrophic events, or WMCE, filing becomes a path to recover remaining costs.
On our securitization filing, hearings beginning in December at the CPUC, and based on the procedural schedule, we anticipate the case could ramp-up in the second quarter of 2021 with a securitized debt offering closely following. We will also be separately preparing our AB 1054-related securitization filing after we receive the final decision in the 2020 General Rate Case.
Looking forward, a last area I'd like to touch on due to the broad public policy focus in California is vehicle electrification. The transportation sector remains the largest emitter of greenhouse gases, accounting for roughly 40% of the total for the state. So the need for emission reductions in this sector is, as part of meeting our statewide carbon reduction goals, is clear.
Our customers' excitement for electric vehicles continues to be reflected in consistent adoption levels. More than 300,000 electric vehicles is plug-in at PG&E's grid, representing 1 out of every 5 electric vehicles nationwide, and you see additional growth due to the increasingly competitive space among OEMs.
Our current CPUC-approved EV charging infrastructure portfolio is one of the largest of any utility in the United States. At this time, we have installed roughly 3,500 ports as part of our Phase I for electric vehicle charge network filing at the CPUC. And as an indicator of our customers' interest, this program is more than 3x oversubscribed. The governor recently issued an executive order for zero-emission passenger vehicles by 2035 and medium heavy-duty vehicles by 2045. And in support of the state's clean energy goals, we anticipate submitting a 10-year transportation electrification plan by early 2022.
Now I'd like to transition to our third quarter financial results. Slide 13 shows the results for the third quarter. Non-GAAP core earnings per share for the year came in at $1.6 billion and is consistent with our full year guidance. GAAP earnings, including noncore items, are also shown here. The noncore items are consistent with the full year 2020 guidance I mentioned.
Moving on, Slide 14 shows the quarter-over-quarter comparison for non-GAAP core earnings of $590 million or $1.11 in the third quarter of last year and $461 million or $0.22 this year. The primary drivers were an increase in shares outstanding from our July 1 equity raise, interest expense as well as 2 timing items that are each expected to reverse. The first is the 2020 General Rate Case cost recovery and second is the timing of taxes.
With a full quarter behind us after the bankruptcy, we're now very focused on executing well on the operational and financial plan we set out. We have a strong earnings projection ahead of us that is supported by regulatory outcomes that I discussed, and we are excited for the long-term opportunities provided from our state's focus on clean energy technology.
With that, operator, could you please open the lines for questions?
Operator
(Operator Instructions) Your next question comes from the line of Stephen Byrd from Morgan Stanley.
Your next question comes from the line of Julien Dumoulin-Smith from Bank of America.
Julien Patrick Dumoulin-Smith - Director and Head of the US Power, Utilities & Alternative Energy Equity Research
Can you hear me now?
Christopher A. Foster - VP & Interim CFO
We can hear you, Julien.
Julien Patrick Dumoulin-Smith - Director and Head of the US Power, Utilities & Alternative Energy Equity Research
So perhaps if I can go back here. Can we talk about the wildfire certification process and just your expectations here? I mean, clearly, both of your peers have it. Certainly, you had articulated some forthcoming deadlines here on obtaining it. Any specific context that you would provide us in thinking about nuances to delays or otherwise as to the process itself, just given where we stand today? And then I have a follow-up.
Christopher A. Foster - VP & Interim CFO
Sure, Julien. No problem. Again, I think as Bill laid out, right, we have filed all the information that we think is relevant that the commission was seeking at this stage. We filed that on July 29. So we do still anticipate a decision from the commission by the end of the month. What I would offer just in terms of context around it because I think there's been a little bit of confusion. There's maybe a couple of ways to think about it.
First, it's important to keep in mind that while the commission is considering that decision, the prior safety certificate remains in place. If we run into a scenario where the commission were not to approve, you'd have a couple of things occurring. First, we would have the ability to continue to have access to the AB 1054 Wildfire Fund, but we will lose the protection of the shareholder liability cap and the improved prudent deconstruct. So just wanted to provide that. We don't anticipate that being the outcome, Julien, but I just wanted to provide that as a way for -- to help you think about what the other scenario could look like.
Julien Patrick Dumoulin-Smith - Director and Head of the US Power, Utilities & Alternative Energy Equity Research
Got it. All right. Excellent. If I can go back. Can you talk a little bit about the scenarios here with Zogg Fire? I know it's difficult to speak to at this point in time. But can you speak a little bit to the context and the decision to make around PSPS? And I know you all provided this context earlier, but can you give a little bit more as to the event as to why you did not engage in PSPS in that specific context there? And again, how that fits into the certification framework as well?
Christopher A. Foster - VP & Interim CFO
Sure, Julien. This is Chris. I think the safety certificate, we would consider largely separate and apart. There was a fairly straightforward set of criteria that the commission was evaluating as it related to the certificate itself. If you look at the situation in terms of the data points around the Zogg Fire, there were 3 different weather stations that were in the general vicinity, which is what we shared with Judge Alsup in our filing this week.
And there, I think what you saw is, generally speaking, the sustained wins were roughly 15 miles per hour in that area, with gusts at certain publicly owned weather stations at up to around, I think, 32 miles an hour. That deviates from what we have in terms of our own planning. As you know, our public safety power shutoff approach consists of a number of different considerations from relative humidity to the moisture and the fuels in the ground, to wind speeds as well.
The wind speeds in those areas did not meet the general requirements that we have in place. You could consider those as roughly 25 miles per hour in terms of sustained winds. And generally speaking, an exceedance of 45 miles per hour in terms of purposes where we would typically consider shutting off at an area that customers are being served by.
Julien Patrick Dumoulin-Smith - Director and Head of the US Power, Utilities & Alternative Energy Equity Research
Got it. Lastly, sorry for another one, but if I could squeeze it in. Just on insurance. Obviously, the market is dynamic. You've obtained more here. Going forward into the next year, what are your options around different avenues here? If you can just elaborate very quickly as to the extent to which that it may not necessarily perpetuate as it has this year?
Christopher A. Foster - VP & Interim CFO
Sure. I guess I would start with I have to acknowledge, it's been a pretty dramatic year, as Bill talked about, in terms of statewide impacts from the August heat, storm, fires and other elements. So it's -- obviously, Julien, the market is going to continue to evolve. I think from a cost recovery standpoint, we do think that we have achieved what is reasonable in terms of insurance coverage for this year.
In terms of next year, I think there are probably a few things at play. Our understanding as we read the statute is that AB 1054 does contemplate the Wildfire Safety Administrator, the entity that oversees the Wildfire Fund to contemplate a level of coverage for the investor on utilities in the state. Absent any kind of explicit guidance there, we'd be looking into next year to determine what would be the most cost-effective coverage options for our customers. Everything from multiyear plan components, some different structures to the insurance itself as well as certainly trying to compete as best we can for the best price possible for customers.
So at this stage, for this year, we do have a total of $1.5 billion in comprehensive coverage. $868 million of that is for wildfire coverage, at a total cost of the $1.5 billion, which comes to roughly $860 million.
Operator
Your next question comes from the line of Steve Fleishman from Wolfe Research.
Steven Isaac Fleishman - MD & Senior Analyst
Just -- I guess a question on the Fire Victim Fund. Have you gotten any indication from them on their intentions in terms of the shares they own and any plans for -- basically what the plans are for those shares going forward?
Christopher A. Foster - VP & Interim CFO
Steve, we haven't this point, what you'll see in our queue is that we did point out that as of October 20, the information the company has is that the trust has not sold any shares. So that really is the update on that front. I think at this stage, obviously, given the Fire Victims Trust is a substantial shareholder of the company, we do our best to communicate openly with them as well to help make sure that they're aware of events around the company. But at this stage, can't really speculate on how they're thinking about share issuances in the future.
Steven Isaac Fleishman - MD & Senior Analyst
Okay. Can you clarify whether they were blacked out at all or anything? Or just not...
Christopher A. Foster - VP & Interim CFO
Sure, Steve. I think it's a fair question. The dynamics there that you should think about going forward are that the registration rights agreement that we do have with the trust provides for blackout periods, some demand rights provisions and other things. But largely, those attributes would not be really in the public domain. Those would be exchanges of information between the company and the Fire Victims Trust. Certainly, at this stage, our interests are very aligned, and so we would want to collaborate with the Trust as appropriate should they undertake an underwritten offering.
Steven Isaac Fleishman - MD & Senior Analyst
Okay. Second question, just -- and this is -- I don't know how way you can answer this. But we've had a lot of events this season and you've done several PSPS. And obviously, most of them have worked very well. We do have the Zogg event, but then a lot of successful events in terms of avoiding issues. So could you -- is there any color you can give on just kind of political regulatory feedback that you're getting on your activity so far?
William L. Smith - Director
Steve, this is Bill Smith. Thanks for the question. I think that, generally speaking, people understand the nature of the challenge that we are facing and the feedback has been relatively good from our key stakeholders. No one likes to see us have to do this, but I've seen, in fact, some articles that kind of recognize that this is about public safety.
And I think as unfortunate as this season has been, if you look at the early part of the season and the number of wildfires we had, that had nothing to do with utilities of any kind, I think it showed the public in general that this is a much broader issue than PG&E. And yes, I think I mean the state of California has said something approaching 9,000 fires so far this year.
So I think there's a better acceptance this year of the nature of the challenge. We've been getting some pretty good feedback from all the key stakeholders that we're executing well. And I would like to say that in the events that we've had this year, while we're still doing some of the final tallies from this latest event, that there've been well over 100 cases where we found debris and other things into our lines that had we not taken the proactive steps to implement a PSPS, could have or would have likely started a fire.
So I think that -- obviously, you point out the Zogg issue, we've got to learn more about that. But I would say generally speaking, what we're doing is working. I think people appreciate that it's for their safety and the safety of the communities.
Steven Isaac Fleishman - MD & Senior Analyst
Great. Just one last quick one, just on the management hires that you're working on. I know you can't probably give specifics, but just given that these are obviously 3 very important roles, could you give us some color on the types of people you're looking at for these different roles? Or are these -- are we going to know these people? Any color there would be helpful.
William L. Smith - Director
Yes. Well, without getting in any detailed specifics, I think what I would say is we're looking for people with experience and a strong commitment to safety and operational effectiveness and basically operational excellence. So I'm really pleased at how that whole process is coming along. So just stay tuned, but it's coming along quite well and very much according to our plan.
Operator
Your next question comes from the line of Jonathan Arnold from Vertical Research.
Jonathan Philip Arnold - Principal
A quick question on the TO20 and just sort of how to think about this going forward. I see -- it looks from the slides as though you're sticking with the rule of thumb sort of guidance modeling to assume the CPUC cap structure and the return across the enterprise. But one feature of the settlement is that you're getting to earn on this hypothetical cap structure.
So Chris, I'm sort of curious whether there is some sort of health embedded within that versus how you were suggesting we approached this before or whether it sort of fits just within the general tolerance?
Christopher A. Foster - VP & Interim CFO
It's consistent, Jonathan. Thanks for the question. I know that the TO20 case has some unique elements to it. But at this age, the thing that I would focus on is the assumption that we've called out. If you specifically look at our 2010 factors, I think you'd want to focus on the AFUDC waiver because that's the piece at this stage. The other elements are fairly straightforward. They're not changing relative to where we were before.
You'd want the AFUDC waiver piece to be handled by the FERC accounting staff reasonably. And a general way to think about that, if it's helpful, Jonathan, is, you'd probably be looking at a $0.03 swing roughly depending on how that turns out. But our assumption as we call out here, implies that we think that we'll have that FERC accounting staff final view by the end of the year.
Jonathan Philip Arnold - Principal
Actually, I did want to follow-up on that, to understand that better. Is that -- does that have an ongoing earnings variance impact? Or it sounded like it might be more retroactive looking -- trying -- looking back. But I'm not sure.
Christopher A. Foster - VP & Interim CFO
It'd be looking back, Jonathan.
Jonathan Philip Arnold - Principal
Okay. So that $0.03 you're talking about is just a swing factor in terms of what you would book as core earnings for '21, but ultimately, it doesn't really change the trajectory. Is that right?
Christopher A. Foster - VP & Interim CFO
So just to be clear, Jonathan, we called it out as an assumption in 2020 specifically. So that's where we would anticipate the impact if it were to go in a different direction.
Jonathan Philip Arnold - Principal
Okay. But that going in a different direction, would that change the go-forward earnings power or just -- impact just 2020?
Christopher A. Foster - VP & Interim CFO
It would be an impact confined to 2020.
Jonathan Philip Arnold - Principal
Okay. Great. That was it. And I think -- and one -- just one thing on insurance. I know you just gave us the total cost. Is there a data point on what you ended up paying for this incremental $100 million?
Christopher A. Foster - VP & Interim CFO
No. There's not specifically, Jonathan. I do appreciate the question because there's been quite a bit of focus on the wildfire component of the coverage itself. We just -- we haven't provided any additional color at this stage. I'd certainly imagine we'll continue that discussion with the CPUC as we examine cost recovery there at this stage. Again, this overlaps with the 2020 General Rate Case proposed decision that we have. And we do hope the commission ultimately, in their final decision, could land at the place where -- in the language that's reflected in our settlement agreement.
Operator
Your next question comes from the line of Michael Lapides from Goldman Sachs.
Michael Jay Lapides - VP
Chris, this one's probably for you. Just curious. There are lots of items that won't necessarily have a direct income statement impact but could lead to significant sources of cash inflow in the CEMA and -- in CA. Can you just walk us through those a little bit because some of these are starting to get pretty material? And I'm just trying to think about things that would be kind of cash inflows for 2021, 2022 that may be more cash flow statement versus income statement drivers.
Christopher A. Foster - VP & Interim CFO
Sure, Michael. I think if you look at it, we call them out as well in our disclosures in the Q, but the way I'd think about it is you have multiple different memorandum accounts that have been stacking up. I want to say it's -- I could be off on this number, so I'm going to be generic. But I think it was roughly in the neighborhood of $2.5 billion to $3 billion have been building up. So I think that's where your focus is.
Ultimately, if you step back, though, these cost recovery mechanisms and the memorandum accounts are something we've been planning around for a few quarters. So I wouldn't think about it as implying there's any kind of change in the financing plan that sits behind it to support it. Because I think, ultimately, if you really start with CEMA, for example, it's been a fairly straightforward cost recovery mechanism for the company for years. We were pleased to see that the interim rate relief request came through that accelerated some of those recoveries, Michael. But otherwise, as you see those broken out, we would contemplate that traditional regulatory lag that exists for California and so it wouldn't necessarily be impacting any kind of future financing.
Michael Jay Lapides - VP
Got it. And then last item, would you guys think about the bill? Meaning, what's going to happen in the customer bill over the next couple of years. Can you talk just directionally what you think the level of bill inflation or deflation you anticipate over the next 3 to 4 years, 3 to 5 years if you look at it to your plan?
Christopher A. Foster - VP & Interim CFO
Sure. So stepping back a bit, Michael, I think it's a good question, right? We have substantial investments needed to mitigate wildfire risk. But in terms of the company's plan, it's actually pretty straightforward. We have the combination of the GT&S case, our cost of capital proceeding, the General Rate Case and now the TO20 case, which really gives us pretty good line of sight to what that's going to look like at least for the next 3 years in most of those examples.
As you start to look at that kind of 3- to 5-year range, we're, generally speaking, looking at roughly 4% to just north of 4% average electric system bundled average rate impacts for our customers. That puts us, generally speaking, in line with growth projections in our state. We are very fortunate to serve the area that we do and the economic diversity that exists here.
And I think there's another way we look at it, as you can imagine, as well. We also contemplate these growth rates as it relates to a percent of share of wallet for customers, right? We acknowledge that our customer base is very different from customers who may live in the Central Valley of California to Northern California, and those in the more moderate and tempered areas in the coastal communities. And so that's the range that we're generally speaking, looking at for the next few years.
Michael Jay Lapides - VP
And finally, are there any major cost saving variance where you think you could offset some of that bill inflation?
William L. Smith - Director
Yes. Thanks. This is Bill. I think there are a lot of areas. I wouldn't say there's a given major place, but there are a lot of opportunities that we think that we can do from taking approach to some of our contracting efforts. When we started after the events of 2017 and 2018, there was a very aggressive attempt to get as many resources on the ground as we could. I think there are ways for us to come back and look at that more effectively.
I think one of the things I'm excited about is the point that I made about the initiative that we're kicking off around some of our operational process improvements. I think there are ways that we can get much more effective at what we do, reduce lost time, take cycle time out, which reduces inventory needs. A lot of things. So I think it's a broad range of areas that can help us get costs out of the business, not any 1 or 2 individual items.
Operator
(Operator Instructions) Your next question comes from the line of Jeremy Tonet from JPMorgan Securities.
Richard Wallace Sunderland - Associate
This is Rich on for Jeremy. Just wanted to start off with kind of circling back on the prior question. Could you provide a little bit more color around these enterprise-wide initiatives that you alluded to earlier? Maybe the magnitude of the impact over the next few years and how this fits with sort of driving earnings versus offsetting customer rates?
Christopher A. Foster - VP & Interim CFO
Sure, Jeremy. So there's a few different ways to look at it. I think stepping back, what I think you're interested in, and I want to be sure I'm responsive our kind of categories as a way to contemplate this. Some categories will be earnings impacting, others would be more specific to benefits to customers. As we look forward to the next few years, some of those categories we've talked about include things like renewable energy credits, right?
If you -- anytime you look at kind of the energy side of the business in that way, we're always searching for savings to make sure that we're cost competitive on behalf of customers, right? So I think benefits that you would see there would accrue to customers.
We also continue to evaluate additional surplus property assets, similar -- largely similar treatment there in a number of those cases where if there's a developed area there, many of those benefits would also accrue back to customers. You can imagine that conversation is really evolving in real time as we look at the COVID-19 impacts and how to think about the future state of kind of the footprint of the company. Obviously, that's the case with our future move as well to Oakland and moving our primary headquarters there as well.
As we think about some of these other elements of work process improvement that Bill alluded to, I think you could see a split there. But ultimately, we see that as being a driver for us going forward in terms of achieving cost savings that will allow us to, in the future, earn our authorized return as we've guided to in 2022.
Richard Wallace Sunderland - Associate
Great. And then just given the current focus on the elections right now, can you provide any early thoughts around your financial plan and sensitivity should corporate tax rates increase?
Christopher A. Foster - VP & Interim CFO
Sure thing. Rich, it's limited in short because of the NOLs that the company has, I think if -- should there be a change and should there be a substantial change in terms of the tax policy, I think, for at least PG&E you'll see limited impacts there.
Operator
Your next question comes from the line of Ryan Levine from Citi.
Ryan Michael Levine - Research Analyst
Can you -- what's the noncore assets the company is starting to sell? And can you remind us the sharing mechanism between ratepayers and shareholders on the potential proceeds? Any more color you're able to share on it.
Christopher A. Foster - VP & Interim CFO
Sure, Ryan. I appreciate the question. And I'm really not able to be much more forthcoming than that. I think it's -- what I emphasized there and where we were really last quarter is, we are really doing the internal work right now to evaluate some small noncore assets that we're evaluating. If you step back and just think about different, what I'll call, asset classes, which is -- you can think about different asset classes in different ways, one of which is the land that the company owns, the physical footprint that we have in different areas, some of which is developed, some of which is not.
Generally speaking, the benefits that accrue from any sale will differ depending on that treatment as one example. As you look across other different asset classes, there could be opportunities where the gain on sale treatment is slightly different. And so at this stage, we are very focused on this effort. I do think we can continue to make progress. But I don't want to be too specific because I don't want to get ahead of our internal work at any kind of outreach we'd otherwise be doing at a later stage.
Ryan Michael Levine - Research Analyst
And then changing gears, what assumptions change that drove the higher Kincade estimate? And given that you haven't received the CAL FIRE report, are there any additional information changes that you're anticipating that we may receive for the revisions to get current estimate?
Christopher A. Foster - VP & Interim CFO
Sure, Ryan. So this is really just an element of time passage and us getting better information over time. At this stage, what we had referenced, we're having conversations, as you can imagine, with some of the different entities. And in particular, what we noted were the subrogation claims themselves. We have better data than we had before. As you recall, with prior -- as you may recall, with prior wildfires in prior years, the California office of insurance had disclosed a greater level of granularity, which provided one means by which to have additional input. In this situation, we have now improved data as it relates to the subrogation claims, in particular, and that allowed us to update our accrual at this stage.
Operator
And there are no further questions at this time.
Matt Fallon;Senior Director, Investor Relations
Well, thank you all for your interest in PG&E, and thank you for joining us on the call today. If you have any follow-up questions, please don't hesitate to reach out to Investor Relations.
Operator
Thank you. Ladies and gentlemen, this concludes today's conference call. Thank you for participating. You may now disconnect.