Prepared Direct Testimony of Robert McCullough on Behalf of the ...

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Page 28 <strong>of</strong> 76SE.4TAC-400on June 19 and 20 to approximately 1000 MW on June 21 and 22. Outages reported to theIS0 for June tells an interesting story. According to the IS0 reports, the days identified in theFERC settlement were among the best days Reliant plants saw thatReliant Forced and Planned Outages in June 2000r- scheduled -Forced IQ. Were these reductions financially beneficial?A. These reduction were not without cost. If Reliant had operated their plants at the rated capacityduring on-peak hours on June 22, they would have netted $1,072,261 in additional pr<strong>of</strong>it.Operating at less than rated capacity on June 21, cost them an additional $858,557 in pr<strong>of</strong>its.Q. Is there evidence that Reliant repeated this withholding behavior?A. Yes. It is relatively easy to check if Reliant frequently made large unexplained s,hifts in generation~ ~'Bxhibit SEATAC402 and 409.
over the period <strong>of</strong> the California crisis. Since we know the changes their generation levels shouldhave made with respect to electric prices, natural gas prices, and NOx prices, we can easilyidentify sudden shifts that can not be explained by these factors. We can expect that major shiftsare unlikely to be explained by a real outage, since this would require multiple units to failsimultaneously.The next chart shows large daily shifts in Reliant generation after changes in market conditionshave been considered.16 For example, a sudden shift in gas prices would normally inducegenerators to reduce output. These changes have been factored into the analysis - as havechanges in other critical prices.Date i ~~~~~~~Generation................ ..................................... ...............1211 1i,271ib60111 112000-1210912000 25/i00.6.! ....................(2.695)bwi11200 006/2.6,2000 , .. . . . . . .(2,097)bi,o.u2diiroiroi,2001. ................... ................ (1,573.......... (1.380) ..........bu2.3 6b;ijo5/2 Ol.mOir' ............................................ (1,105).iij~~j~~o&1lj27/2000I,200&,oi6w ... .................. (1,016)............................. .......- .................... (1,003)12/13/2000-12/12/2000...._ ..!........... '......................... (760)0~2sl2001-05/28/2001............................................................'("8,07115/2000711412000 i................................ (738)..................... (693).................................. (687)"""-. ..................... (678).................... (683)1658)As can be readily seen, Reliant generation <strong>of</strong>ten exhibited large changes that could not beexplained by market conditions. In each case, Reliant's generation reduction was enormously'Bxhibit SEATAC402 and 41 1.
Page 1 and 2: Page 1 of 76SEATAC
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Page 5 and 6: summarizes their conclusions as:The
Page 7 and 8: where as last week we were $70.00,
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Page 13 and 14: 1 Q. How did the individual compani
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Page 41 and 42: Death StarsThe schedules of
Page 51 and 52: Page 5 1 of 76SEAT
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Page 75 and 76: Have you conducted this analysis fo
Page 77: CERTIFICATE OF SERVICEI hereby cert

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