Related to the utility-owned fossil generation and related outages, ORA made four recommendations, listed below, which ORA states were agreed to by PG&E. ORA requests the Commission to memorialize PG&E’s agreement. PG&E does not dispute agreement to these recommendations but , offers refinements and clarifications. PG&E agrees to prepare an incident report following the forced outage of any unit at any one of its generating facilities over 25 megawatts. PG&E had originally agreed to include supplemental testimony regarding an outage at the Humboldt Bay Generation Station (Humboldt). Instead, PG&E corrected the master data response and, thus, ORA is satisfied with the correction and no longer requests a supplemental filing. ORA recommends the Commission require PG&E to update the Commission on the company’s implementation of the Environex Report recommendations. Instead, PG&E proposes that it provide a report to ORA in response to a data request in next year’s proceeding. ORA recommends PG&E perform a cost-effectiveness analysis of whether Humboldt should be shut down by Instrumentation and Control devices instead of manually. PG&E explains that the use of these devices would increase outages thereby increasing costs. ORA accepted PG&E’s explanation and requested the Commission find PG&E in compliance with industry standard when an Instrumentation and Control device indicates high emissions. We address recommendation numbers three and four, as there appears to be some need for clarity. For recommendation number three above, there appears to be a difference of opinion with respect to how the Commission should be updated on PG&E’s implementation of the Environex Report: ORA recommends PG&E provide a
Related to the utility-owned fossil generation and related outages, ORA made four recommendations, listed below, which ORA states were agreed to by PG&E. ORA requests the Commission to memorialize PG&E’s agreement. PG&E does not dispute agreement to these recommendations but , offers refinements and clarifications. PG&E agrees to prepare an incident report following the forced outage of any unit at any one of its generating facilities over 25 megawatts. PG&E had originally agreed to include supplemental testimony regarding an outage at the Humboldt Bay Generation Station (Humboldt). Instead, PG&E corrected the master data response and, thus, ORA is satisfied with the correction and no longer requests a supplemental filing. ORA recommends the Commission require PG&E to update the Commission on the company’s implementation of the Environex Report recommendations. Instead, PG&E proposes that it provide a report to ORA in response to a data request in next year’s proceeding. ORA recommends PG&E perform a cost-effectiveness analysis of whether Humboldt should be shut down by Instrumentation and Control devices instead of manually. PG&E explains that the use of these devices would increase outages thereby increasing costs. ORA accepted PG&E’s explanation and requested the Commission find PG&E in compliance with industry standard when an Instrumentation and Control device indicates high emissions. We address recommendation numbers three and four, as there appears to be some need for clarity. For recommendation number three above, there appears to be a difference of opinion with respect to how the Commission should be updated on PG&E’s implementation of the Environex Report: ORA recommends PG&E provide a
214204879.docx