ML030500300
| ML030500300 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/07/2003 |
| From: | Bowen B 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: ML030500300 (3) | |
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=.15 16 In re PACIFIC GAS AND ELECTRIC COMPANY, a California corporation, Debtor.
Federal I.D. No. 94-0742640 Case No. 01-30923 DM Chapter 11 Case Date:
Time:
Place:
February 27, 2003 1:30 p.m.
235 Pine Street, 22nd Floor San Francisco, California DECLARATION OF BRUCE R. BOWEN IN SUPPORT OF FOURTH MOTION FOR AUTHORITY TO INCUR MISCELLANEOUS IMPLEMENTATION EXPENSES (I
DECLARATION OF BRUCE BOWEN JAMES L. LOPES (No. 63678)
JULIE B. LANDAU (No. 162038) 51 VS 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 17 18 19 20 21 22 23 24 25 26 27 28 A
wet /
1 I, Bruce R. Bowen, declare:
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- 1.
I am Director of Regulatory Analysis for Pacific Gas and Electric 3
Company ("PG&E"), the debtor and debtor-in-possession in this Chapter 11 case, and have 4
been employed by PG&E since
. I am also the project manager for 5
implementation of the Human Resources Management System in connection with the 6
implementation of PG&E's proposed Plan of Reorganization (as amended from time to time, 7
the "Plan"). This declaration is submitted in support of PG&E's Fourth Motion for 8
Authority to Incur Miscellaneous Implementation Expenses (the "Motion"). Defined terms 9
used herein shall have the meanings set forth in the Motion. I make this declaration from 10 personal knowledge and if called as a witness, could and would testify competently to the 11 matters set forth herein.
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- 2.
PG&E previously filed a Motion for Authorization to Incur Human HORD 13 Resources Management System Expenses on May 10, 2002, which was approved by Order ckmw 14 entered on May 31, 2002. In the previous motion, PG&E explained that the New Entities 15 would require human resources and payroll systems to support the payroll and related 16 functions needed for a company employing thousands of employees with benefits 17 comparable to PG&E's existing benefits, and the restrictions of collective bargaining 18 agreements among other complexities. Further, PG&E explained that the New Entities 19 would use an integrated human resources system to be implemented by PeopleSoft, Inc. and 20 referred to as the Human Resources Management System ("HRMS"). PG&E anticipated at 21 that time that approximately $2.2 million would be required for the HRMS implementation 22 in connection with PeopleSoft's services.
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- 3.
Since May 2002, PeopleSoft has been working on the HRMS project. As 24 explained in more detail below, the HRMS project has proven more complex and time 25 consuming than either PeopleSoft or PG&E had anticipated at its inception in May 2002.
26 PG&E now estimates that an additional $425,000 will be required for the HRMS project.
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The reasons for the increased costs on this project include: (i) more HRMS 28 software customization is required than originally anticipated as a result of a more complete DECLARATION OF BRUCE BOWEN 1
understanding of the factors used to implement collective bargaining agreements relating to 2
compensation of union employees, as well as a more complete understanding of the New 3
Entities' business requirements; (ii) more work is involved than originally anticipated in 4
building internal and external interfaces between HRMS and other systems or organizations 5
(internal interfaces include links to the general ledger and to the group handling workers' 6
compensation matters; external interfaces include links to benefits providers, 401(k) 7 financial managers and payroll tax service providers); (iii) more work is required than 8
originally anticipated in connection with adapting the HRMS to handle data conversion and 9
benefits enrollment activities over a period of time; instead of using a traditional cutover 10 plan (converting all data at one time), PG&E requires a complex set of data conversion 11 activities to permit identification and conversion of non-bargaining unit and bargaining-unit 12 employee data at different times, and also to convert payroll and benefits data at different 13 times; and (iv) PG&E has not been able to devote as many internal resources to this project RKI mR14%7 14 as originally anticipated, which has increased PeopleSoft's time spent on the project.
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PeopleSoft will continue to work on this project under the same contract 16 terms as before, which allow PG&E to terminate the contract at any time upon 14 days 17 written notice, without cause, in which case PG&E is liable only for services performed by 18 PeopleSoft to the date of termination.
19 I declare under penalty of perjury of the laws of the United States that the 20 foregoing is true and correct, and that this declaration was executed at San Francisco, 21 California on February 7, 2003.
22 23 BR IfR. BOWEN 24 WD 020503/1-1419905/1054205/vi 25 26 27 28 DECLARATION OF BRUCE BOWEN