ML022350439

Declaration of Lance Maeda in Support of Motion for Authority to Incur Miscellaneous Implementation Expenses

ML022350439
Person / Time
Site:	Diablo Canyon
Issue date:	08/15/2002
From:	Maeda L 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: ML022350439 (6)

Text

JAMES L. LOPES '(N. 63678)

JANET A. NEXON (No. 104747)

JULIE B. LANDAU (No. 16203&}.

.s *.

HOWARD, RICE, NEMEROVSKI, CANADY, FALK & RABKIN - "

A Professional Corporation Three Ermbarcaderp Center 74*i Floor San Francisco, C~aif6mia

-1.1 1-4065 Telephone:

415/434-1600-,'.'.-,.

Facsimile:

415/217-5910 3.3 1

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,,,,..15 16 17 18 19 20 21 22 23 24 25 U)NITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION Case No. 01-30923 DM.

In re PACIFIC GAS AND ELECTRIC COMPANY, a California corporation, Debtor.

Federal I.D. No. 94-0742640 Chapter 11 Case Date:

September 4, 2002 Time:

9:30 a.m.

Place:

235 Pine Street, 22nd Floor San Francisco, California DECLARATION OF LANCE MAEDA IN SUPPORT OF MOTION FOR AUTHORITY TO INCUR MISCELLANEOUS IMPLEMENTATION EXPENSES j

DECLARA&TION OF LANCE MAEDA I

Attorneys for Debtor and Debtor in Possession PACIFIC GAS AND ELECTRIC COMPANY 26 27 28

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23 24 25 26 27 28, I, Lance Mae-da, declaie:

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I am, employed by -Pacific Gas and Electric Company ("PG&E"), the debtor and debtor-in-possession in this-Chapter 11 case.. have been employed by PG&E since 1996 and hold the position of Director of Application Development & Support. In this position,' famr responsible for technical oversight of information technology ("IT") software projects withifi PG&E's Infoimation Systems and Technical Services Organization; I also have company-wide responsibilities in the IT area, including responsibility for creating and implementing plans, policies -nd procedures forPG&E's IT software activities and for supervising employees'engaged in systems development and support functions. In connection :with implementation of PG&E'sproposed Plan of Reorganization (as amended from time to time; the -"Plan"), my specific responsibilities include: identification of applications that will be needed by the New Entities, integrated testing of applications migrating from PG&E to the New Entities, and defining security strategies for applications to be used by tlhe New Entities.'

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This declaration is submitted in support of PG&E's Motion for Authority to Incur Miscellaneous Implementation Expenses (the "Motion"). Defined terms used herein shall have the meanings set forth in the Motion. I make this declaration based on peisonal knowledge, ex&ept where otherwise indicated, and if called as a witness, could and would testify competently to the matters set forth herein.

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Intranet Development: As indicated in PG&E's previous Motion to Incur Information T'echnol6gy Consulting Expenses, PG&E will use IT consultants to create an Intranet for the New Entities. The existing PG&E Intranet is an essential tool for employees, functioning as a cenitralized portal and repository for accessing web-enabled applications and providing employees with tools, services and information needed for daily business operations, (e.__,

timesheets; job bidding; electric control systems; safety, health and claims policies and prdcedtires; employee benefits and payroll information; and regulatory and compliance information). To enable the employees of the New Entities to create, maintain

',and publish Intranet content for all of the foregoing purposes, PG&E will obtain software "DECLARATION OF LANCE MAEDA 1 9

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1 licenses for TeamSite an&Otetn Deploy. TeamSite is dociirrient management software that 2

allows for construction'of do6cument templates.and storage.of Internet content. Open Deploy 3

is software that allows for "dontent updating to an Internet seryer. PG&E will also require the 4

servicei&of ITconsiiltants to configure andinstall this software. The IT consultants will also 5

develop content templates (to ensure consistency of format used for data entry onto Internet 6

enabled forms), migrate approximately 200 pages ofcontent from PG&E's existing Intranet 7

to the New Entities'-Intranet,'and provide training materials.

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The sbftware licejises will be obtained from Interwoven, Inc., a software 9

vendor, at a cost of approkimately S85,000. For the consulting work, PG&E will utilize 10 approximatelyi10 technical 6ofisultantsito be hired through Sapient, a firm specializing in 11 appli*atiofi de*,eloýfmerii a-nd'software package integration, at an estimated cost of $300,000.

12 Because the Initranet will pr6vide critical information and functions for employees of the' HOWM 13 New Entities, PG&E believes-thbt the new Intranet must be operational in advance of the cmw 14 Effective Date urider the Plafr(the "Plan Effective&Date"). The work to be performed by 5

Sapient is-expected to take two m6nths for completion. In addition, PG&E anticipates that 16 the software products will not be delivered for at least one month after PG&E places its 17 order, following approval of this Motion. Finally, after completion of the work to be 18 performed by',Sapient, PG&E w'Ill require additional time to complete the content 19 development process for'the new.Intrariet.--.

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5. : Ap~lication.Integration." One of the key business systems utilized 21 throughout PG&E t6day is the SAP system, which includes accounting and purchasing 22 functiohs. PG&E intends tb build a second copy of.the SAP system to manage the "23 operatiofia iahd accouniing-functions for.the New.Entities. The New Entities will also be 24 using two ojhei key business systems:,(i) the human resources management system 25

("HRMS"), a hfimf riesources and payroll management system (PG&E previously obtained 26 th Co6urt's a'pprv al to pay consulting fees in connection with the implementation of the 27 HRMS); and (ii) the Plant Information Management System ("PIMS") currently used by the 28 Diablo 'Canyon Power Plant. These three critical business systems must all be integrated DECLARATION OF LANCE MAEDA 1

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,Ah*.d O 15 16 17 18 19 20 21 22 23 24 25 26 27 28 (i.e., connected ý6 tfiat information can be shared and distributed between and among the three systems) i order for the New-Entities.to effectively utilize these systems. The integration of tlie'se sy-stems'iequires certain integration technology, as described below, without whiiclh PG&E wvould need to develop custom interfaces to accomplish the data sharing at a higher' 6bst and without the level of flexibility provided by the integration technology.

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Inf drder to ac5complish the systems integration, PG&E will purchase software licenses from BEA Syste'ms,; Inc., a software applications consulting firm, for a cost of approximately $66,600. The, sQftware includes BEA WebLogic JCA Adapter for Mainframe'and BEA:-_ WebLogic Utility Adapter Package as well as maintenance support for these products. The s6ftware licenses will be transferable to the New Entities. In addition, a technical consultant will be needed to, assist with the integration (including design, set-up and testing of the various softwa're products), and the design, building, testing and implementation 6f the interfaces between SAP,, HRMS and PIMS. The consultant will also provide on-site traifning. The'consultant will be hired from BEA Systems, Inc. at an estimated cost of $200,000.

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'Tfhie New Entities will require the integration of these three key systems in advance of the Plan Effective Date in order to commence business operations. The work to be performed by BEA is expected to take'two months for completion and will begin within one month followiiig approval of this Motion. After, completion of the work to be performed by BEA, PG&SE will require additibnal time, in advance of the Plan Effective Date, to ensure that the systems infegration is fully functional..

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Ifrvestof Relations Website. Currently, PG&E's parent corporation, PG&E Corporation, has a "Veebsite'with an investor relations section that is used daily by large numbers of shadreholders; bondholders and other interested parties seeking accurate and current financial information about PG&E Corporation and its subsidiaries, including PG&E. By the Plan Effeýtive Date, PG&E and PG&E Corporation will be legally separate.

Under the' Plan, separate shares of stock in PG&E will be distributed to all those holding DECLARATION OF LANCE MAEDA yJ

I stock in PG&E Corporation:,Since the §tock willbetfreely taded, there will be two different 2

groups of shareholders in tlh` two c6rpofationsas well as diftinct groups of bondholders and 3

other investors. PG&E's website'Wll be independent of PG&E.Corporation's website, and 4

each will need to have a separate invýestor relations section containing current and accurate 5

information for shareholders; inv'estors and'other interested parties who rely on the websites 6

for this information.

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Evers6 Corporatiorn, a -web design and development'firm, will be utilized to 8

design a new investor relations secti6n of the PG&E websjite.,The number of Everse 9

employees who N*ill work on this pi6j 6ct will'vary at different phases of the project, but it is 10 expected that two to'four individuidlsw'ill be working on the project at any given time, 11 including website designers, programmers, project leaders and production artists. The Everse 12 employees will gathei information about business requirements, design the new investor 13 relations section of PG&E's website; code the applications and content (including both text NY 14 and graphics) for the site pages, integrate the content with the current website content, train 15 PG&E employees to use and update this 'section of the website, and arrange for the site 16 pages to be available to members of the public visiting PG&E's website. The total estimated 17 cost for this work is $105,000. In order for the investor relations portion of PG&E's website 18 to be fully operational by the'Plari Effective Date and to begin pr-oviding information to 19 investors following confirmation of the Plan, it isnecessary that the work begin promptly.

"20 PG&E expects thaf this 1prbject will take appibximately three months for completion.

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PG&IE's standard contractual provisions. in place4 (or to be included in any 22 contracts to be executed) with Sapient, BEA'Systems, Inc. and Everse Corporation do not 23 guarantee future work or any minimum ambunt of revenue. PG&E also maintains,the right 24 to terminate the work' at any time withoutcause; in -which case PG&E is liable only for work 25 performed to the date of termifiationf plus costs'reasonably incurred by the consultant in 26 terminating any work in pr6gress.

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-The cost estimates set forth herein are based on PG&E's initial scoping of 28 the project requirements and negotiations with the consultants who have been selected to DECLARATION OF LANCE MAEDA 1

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--fr perform the services.

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 August 15, 2002.

LANCE MAEDA WD 08130211-1419905/1016238/vl DECLARATION OF LANCE MAEDA