PPL/102Godfrey/1Supplemental Testimony of David J. Godfrey
Q. Please state your name, business address, and present position with
PacifiCorp dba Pacific Power (the “Company”).
2A. My name is David J. Godfrey, my business address is 1407 West North Temple,3Suite 320, Salt Lake City, Utah, and my position is Director, Asset Management4and Compliance for PacifiCorp Energy.5
Q. Have you previously filed testimony in this case?
6A. Yes. I filed direct and rebuttal testimony in this case.7
Q. What is the purpose of your supplemental testimony?
8A. I discuss two issues: (1) the non-comparable and non-verifiable nature of the9NERC data Staff proposes to use in its benchmarking proposal for forced outage10rates; and (2) technical problems with Staff’s proposed benchmarking proposal11for forced outage rates, including the fact that Staff set the 90 percent benchmark 12level based upon a “visual interpretation” instead of statistical analysis and that13Staff proposes a mismatched comparison of one year of plant data to a four-year14benchmark, instead of comparing four years of plant data to a four-year15benchmark. I also present an analysis of Staff’s benchmarking proposal and16PacifiCorp’s alternate proposal for excluding extreme events from the forced17outage rate.18
Excluding Extreme Events from Forced Outage Rates
Q. Please explain your general concerns about the use of NERC data in Staff’s
21A. NERC generally supplies information on a summary level, meaning average unit-22year statistics. NERC can provide a frequency distribution of performance indices23