ML022120099
| ML022120099 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/23/2002 |
| From: | Maggard S - No Known Affiliation, Howard, Rice, Nemerovski, Canady, Falk & Rabkin, Pacific Gas & Electric Co |
| To: | Office of Nuclear Reactor Regulation, US Federal Judiciary, Bankruptcy Court, Northern District of California |
| References | |
| 01-30923 DM, 94-0742640 | |
| Download: ML022120099 (6) | |
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- 'RA.H~1N 15 16 17 In re PACIFIC GAS AND ELECTRIC COMPANY, a California corporation, Debtor.
Federal I.D. No. 94-0742640 Case No. 0 1-30923 DM Chapter 11 Case Date:
Time:
Place:
August 12, 2002 9:30 a.m.
235 Pine Street, 22nd Floor San Francisco, California DECLARATION OF STEPHANIE MAGGARD IN SUPPORT OF MOTION FOR AUTHORITY TO INCUR INFORMATION TECHNOLOGY CONSULTING EXPENSES
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DECLARATION OF STEPHANIE MAGGARD JAMES L. LOPES (No. 63678)
JANET A. NEXON (No. 104747)
JULIE B. LANDAU (No. 162038)
HOWARD, RICE, NEMEROVSKI, CANADY, FALK & RABKIN A Professional Corporation Three Embarcadero Center, 7th Floor San Francisco, California 94111-4065 Telephone:
415/434-1600 Facsimile:
415/217-5910 Attorneys for Debtor and Debtor in Possession PACIFIC GAS AND ELECTRIC COMPANY UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION 18 19 20 21 22 23 24 25 26 27 28 Wý- r.1
1 I, Stephanie Maggard, declare:
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I am a director in PG&E Corporation's finance department, and am 3
currently on assignment to Pacific Gas and Electric Company ("PG&E") in connection with 4
the implementation of PG&E's proposed Plan of Reorganization (the "Plan"). I was 5
employed by PG&E from 1989 to 2000 and transferred to PG&E Corporation in 2000. I 6
held a number of positions at PG&E, primarily in the areas of regulation and ratemaking, 7
and business and financial planning. In my current assignment, I am a project manager for 8
PG&E's implementation of the Plan. In this position, I manage the business aspects of Plan 9
implementation, including resolution of business issues, forecasting and tracking of 10 implementation costs, and obtaining any necessary management and court approval for 11 implementation projects.
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This declaration is submitted in support of PG&E's Motion for Authority 13 to Incur Information Technology Consulting Expenses (the "Motion"). Defined terms used RIM EZm 14 herein shall have the meanings set forth in the Motion. I make this declaration based on
&RABMO AAI.,*
C 15 personal knowledge, except where otherwise indicated, and if called as a witness, could and 16 would testify competently to the matters set forth herein.
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PG&E is seeking authority to lease office space for the IT Equipment 18 Project and IT Applications Project described in the Motion. This space will be sublet from 19 PG&E's affiliate, PG&E National Energy Group ("NEG"), which has leased several floors 20 at 345 California Street and no longer requires one of the floors. PG&E seeks to sublease 21 the 23rd floor (16,935 square feet) at NEG's cost on a month-to-month basis. The monthly 22 cost will be $76,700, which includes utilities, taxes and office furniture. PG&E believes that 23 the sublease is reasonable, based on the following factors: (i) PG&E did not incur any 24 expenses in locating the space and negotiating the sublease; (ii) the space is completely built 25 out with tenant improvements, including cabling, furniture, office equipment (e.g. copiers, 26 fax machines, and telephones), and conference space; (iii) the space is conveniently located 27 near PG&E's other offices in downtown San Francisco; and (iv) PG&E retains the ability to 28 terminate the sublease at any time on 30 days' notice. The IT Equipment will be installed in DECLARATION OF STEPHANIE MAGGARD 1
and the IT consultants will work in this space, along with internal staff who are working on 2
the IT Equipment Project and the IT Applications Project. PG&E seeks authority to incur 3
the monthly sublease expense beginning August 1, 2002 and continuing to the Effective 4
Date under the Plan.
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Attached as Exhibit A hereto is a summary of the previously filed 6
implementation expense motions as well as motions that PG&E anticipates bringing to 7
approve additional implementation expenses ("Future Motions"). The Future Motions 8
represent PG&E's current estimate of additional implementation costs requiring Court 9
approval. Because the costs for these activities are uncertain at this time, the summary 10 provides a range of estimated expenditures for each category. The costs are uncertain for a 11 number of reasons, including: (i) the scope of the projects has not yet been finalized, (ii) the 12 specific consultants needed to perform the work have not been identified, and (iii) the timing VRK 13 for the projects is still under review. Finally, PG&E has only estimated these costs through NcýANM 14 December 31, 2002. Depending on when Plan confirmation occurs and when the Effective A
ýc- =15 Date occurs, PG&E may incur additional costs beginning January 1, 2003 that require Court 16 approval.
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The following is a description of each of the Future Motions listed on 18 Exhibit A.
19 (a) Other Information Technology Work: PG&E anticipates that there will be 20 additional IT-related work that is not included in the Motion. PG&E estimates that it will 21 incur between $2.0 and $4.0 million in connection with the additional IT work. These 22 projects will include: additional IT consultants for infrastructure and program applications 23 for the New Entities; internet security applications for the New Entities and PG&E; and data 24 transfer, replication and verification for the PeopleSoft and other new applications that will 25 be used by the New Entities.
26 (b) Facilities, Fleet and Materials: PG&E estimates that it will incur between 27
$3.7 and $5.6 million to separate its facilities, fleet, and materials among the New Entities 28 and PG&E. These projects will include: the transfer of vehicles to the New Entities; DECLARATION OF STEPHANIE MAGGARD 1
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- 15 16 17 18 19 20 21 22 23 24 25 26 27 28 separation of employees in the general office complex in San Francisco; separation and consolidation of employees in field facilities and service centers throughout PG&E's service territory; and the partition and separation of employees at facilities that will house both employees of the New Entities and PG&E.
(c) Records, Maps and Drawings (RMD): PG&E estimates that it will incur between $1.2 and $1.7 million to separate its RMD between the New Entities and PG&E.
These projects will include: identification and separation of RMD located at the Brisbane records center; identification and replication of RMD for the New Entities that cannot be shared with PG&E; sorting and copying of RMD at the centralized storage facility in the general office; and identification and replication of RMD at field offices throughout PG&E's service territory. It is anticipated that only business critical documents will be copied prior to the Effective Date of the Plan.
(d) ETrans Business Processes: PG&E estimates that it will incur between
$800,000 and $1.2 million to implement various ETrans business processes. These projects will include: development of a customer information service database for ETrans customers; and performance of various operations-related activities, such as changing locks at all substations.
(e) GTrans Business Processes: PG&E estimates that it will incur between $1.0 and $1.6 million to implement various GTrans business processes. These projects will include: preparation and modification of GTrans customer contracts for gas transportation and banking agreements; and transfer and modification of gas transmission system maps and engineering records at facilities such as regulator stations where GTrans connects to PG&E's distribution system.
(f) PG&E Business Processes: PG&E estimates that it will incur between
$300,000 and $500,000 to implement various PG&E business processes. These projects will include: replication of applications and IT processes that are now solely provided by PG&E Corporation (related to departments such as Banking and Money Management and Insurance); and reconfiguration of PG&E's Internet page and other customer communication DECLARATION OF STEPHANIE MAGGARD 1
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(g) Newco Business Processes: PG&E estimates that it will incur between $1.8 and $3.2 million to implement various business processes for the benefit of the New Entities.
These projects include: the preliminary work to establish a new identity for the New Entities and implementation of various business processes that are needed to support the New Entities, including the creation of a supply chain management process for purchasing and various accounting and financial functions.
I declare under penalty of perjury of the laws of the United States that the foregoing is true and correct, and that this declaration was executed at San Francisco, California on July 23, 2002.
EXHIBIT A Date of
ýIMPLEMENTATION EXPENSE MOTIONS Costs Hearing Filing APPROVED BY COURT:
Date 4/12/02 Motion re land-related expenses
$5,500,000 5/9/02 4/19/02 Motion re permit and franchise expenses
$ 3,950,000 5/9/02 4/30/02 Motion re procurement expenses
$3,980,000 5/20/02 4/30/02 Motion re benefit program expenses
$1,370,000 5/20/02 5/10/02 Motion re human resources management system
$2,200,000 5/30/02 5/24/02
ýMotion re data management expenses
$ 1,065,000 6/20/02 5/24/02 IMotion re additional permit expenses
$7,000,000 6/20/72 5/31/02 Motion re FERC license expense for Hamilton Branch
$1,000,000 6/20/02 6/12/02 Motion re information technology equipment
$6,400,000 7/2/02
!TOTAL APPROVED COSTS
$32.465.000 Date of IMPLEMENTATION EXPENSE MOTION PENDING:
Costs Hearing Filing Date 7/23/02 Motion re information technology consulting expenses
$6,310,400+
8/12/02
$76,700 per month for lease Anticipated IMPLEMENTATION EXPENSE MOTIONS Anticipated Costs Anticipated Date of ANTICIPATED:
$Millions Date of Filing Hearing 8/8/02 Other information technology work
$2.0 to 4.0 8/28/02 8/15/02 Facilities, Fleet and Materials
$3.7 to 5.6 9/4/02 8/15/02 Records, Maps and Drawings
$1.2 to 1.7 9/4/02 8/8/02 ETrans Business Processes
$0.8 to 1.2 8/28/02 8/8/02 GTrans Business Processes
$1.0 to 1.6 8/28/02 8/8/02 PG&E Business Processes
$0.3 to 0.5 8/28/02 8/15/02 New Entities Business Processes
$1.8 to 3.2 9/4/02 TOTAL ANTICIPATED COSTS
$10.8 to 17.8