According to my interpretation of the most recent documents on the PWC site, here is what PSN is asking for in the new Application. I will admit that I have spent alot of time on this recent set of documents and I may have gotten something wrong as my post has completely changed from my orginal draft:
1) According to the newest Cassidy affidavit, PSN has curtailed but not completely abandoned the standing of tanks! I therefore assume that PSN will be laying off more staff!
2) They are asking the courts for the removal of the "cap" from the New KERP! Now what exactly are they asking here? Keep in mind that the Incentative Pool is based upon a percentage of the collection of accounts receivable. TWM gets 2/3's of the IP and the remaining 1/3 goes to the eligible employees. The most an individual eligible employee can receive is "capped", which is based on the Old KERP agreement. So, are the remaining eligible employees going to get even bigger bonuses from here on out.
3) They are asking the courts that EYO be confirmed as being protected from any claims or liability with respect to it's performance of obligations under the Solicitation Process! This too is odd. I wonder if the court case with New Wave Energy had anything to do with this request?
Personally, I can't see the judge approving the changes to the New KERP...