ML022120106

Declaration of Terrence L. Goodell in Support of Motion for Authority to Incur Information Technology Consulting Expenses

ML022120106
Person / Time
Site:	Diablo Canyon
Issue date:	07/23/2002
From:	Goodell T - 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, 94-07420640
Download: ML022120106 (4)

Text

1 JAMES L. LOPES (No. 63678)

JANET A. NEXON (No. 104747) 2 JULIE B. LANDAU (No. 162038)

HOWARD, RICE, NEMEROVSKI, CANADY, . )f.../

3 FALK & RABKIN A Professional Corporation 4 Three Embarcadero Center, 7th Floor San Francisco, California 94111-4065 5 Telephone: 415/434-1600 Facsimile: 415/217-5910 6

Attorneys for Debtor and Debtor in Possession 7 PACIFIC GAS AND ELECTRIC COMPANY 8

UNITED STATES BANKRUPTCY COURT 9

NORTHERN DISTRICT OF CALIFORNIA 10 SAN FRANCISCO DIVISION 11 Case No. 01-30923 DM In re 12 Chapter 11 Case PACIFIC GAS AND ELECTRIC 13 COMPANY, a California corporation, August 12, 2002 HOVRD Date: 9:30 a.m.

"A 14 Time:

Debtor. Place: 235 Pine Street, 22nd Floor NJK San Francisco, California 15 Federal I.D. No. 94-0742640 16 17 18 DECLARATION OF TERRENCE L. GOODELL IN SUPPORT OF MOTION FOR AUTHORITY TO INCUR 19 INFORMATION TECHNOLOGY CONSULTING EXPENSES 20 21 22 23 24 25

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27 28 DECLARATION OF TERRENCE L. GOODELL

1 I, Terrence L. Goodell, declare:

2 1. I am employed by Pacific Gas and Electric Company ("PG&E"), the debtor 3 and debtor-in-possession in this Chapter 11 case. I have worked for PG&E since 1986 and 4 have been a permanent employee since 1989 working in various engineering and related 5 positions. From November 1995 to May 1997, I had responsibility for the settlement of 6 wholesale electric power transactions between PG&E and various power marketers. From 7 November 1997 to April 2000, I worked as an energy trading consultant and was involved in 8 the implementation of the deregulated market and procurement of electricity for PG&E's 9 retail load. Since April 2000, I have supervised the PG&E personnel that settle the electric 10 energy and transmission-related transactions for PG&E's wholesale transmission customers.

11 Since January 2002, I have been the Team Lead for implementing the billing and settlement 12 functions required by ETrans LLC ("ETrans") in connection with PG&E's proposed Plan of HOWARD 13 Reorganization (as amended from time to time, the "Plan"). In this position, I have

" 14 developed the IT systems requirements for ETrans billing and settlement functions.

, 15 2. This declaration is submitted in support of PG&E's Motion for Authority to 16 Incur Information Technology Consulting Expenses (the "Motion"). Defined terms used 17 herein shall have the meanings set forth in the.Motion. I make this declaration based on 18 personal knowledge, except where otherwise indicated, and if called as a witness, could and 19 would testify competently to the matters set forth herein.

20 3. The following applications-related work is required for ETrans LLC 21 ("ETrans"), the New Entity that will carry on the electric transmission line of business:

22 a. Applications related to Billing & Settlements. In connection with 23 implementation of the Plan, ETrans and PG&E will enter into an Electric Energy 24 Determination and Billing Agreement to handle billing and settlements for electric 25 transmission service provided by ETrans to PG&E. Implementing this agreement will 26 require revisions to existing IT applications and development of new IT applications related 27 to electric transmission service, including applications related to the transfer of meter data.

28 IT consultants will design, develop, install and test the systems necessary to implement this DECLARATION OF TERRENCE L. GOODELL 1 agreement.

2 b. Customer Service Applications. ETrans will need to implement a customer 3 information system to facilitate serving its customers. IT consultants will design, develop, 4 install and test the systems necessary to support ETrans' customer service requirements.

5 4. The following IT consultants will provide assistance related to the ETrans 6 application projects described in Paragraph 3 ("ETrans Work"). PG&E will hire seven 7 application and/or database developers and an associate director who will supervise their 8 work through Blackstone Technology Group ("Blackstone"), an IT consulting firm 9 specializing in the utility business. The application and database developers will design and 10 develop customer information, billing and settlement systems. The scope of work includes 11 developing system designs, applications, and test plans; performing quality assurance; 12 documenting programming codes; and preparing user manuals. The associate director will 13 act as supervisor; he or she will perform such supervisory tasks as monitoring the quality of TAOo14 the work, keeping it on schedule, and making regular reports on the status of the work.

YRAHON 15 Certain Blackstone consultants began work on this project in June 2002 to assist PG&E in 16 determining the -scope of the ETrans Work to~be performed. No payments have been made 17 to Blackstone for the ETrans Work pending Court approval.

18 5. The total estimated cost for the services of the Blackstone consultants 19 described in Paragraph 4 is $928,000. This cost is based on the estimated number of hours 20 required for the project, the applicable hourly rates and estimated reimbursable expenses.

21 6. PG&E's standard contractual provisions in place with Blackstone do not 22 guarantee any future work or any minimum amount of revenue. PG&E also maintains the 23 right to terminate the work at any time without cause, in which case PG&E is liable only for 24 work performed to the date of termination plus costs reasonably incurred by Blackstone in 25 terminating any work in progress.

26 7. The ETrans Work is necessary and must be completed in advance of the 27 Effective Date under the Plan in order for ETrans to commence business operations. The 28 ETrans Work requires the assistance and expertise of the Blackstone IT consultants and may DECLARATION OF TERRENCE L. GOODELL 1 take up to six months to complete.

2 I declare under penalty of perjury of the laws of the United States that the 3 foregoing is true and correct, and that this declaration was executed at San Francisco, 4 California on July 23, 2002.

5 6 #errenceL. Goodell 7 WD 071702/1-1419905/1010310/vI 8

9 10 11 12 HOVARD 13 RKE CANUV 14 UkALKU 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF TERRENCE L. GOODELL