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

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1 Intertie. For this to work, power flows must be generally southward - a standard situation inI.Figure 18 Example Death Star TransactionsOnly the portions at Mead and within Oregon are outside <strong>of</strong> the KO's scheduling.'sSchemes Death Star Workpapm, Exhibit SEATAC426.
Page 45 <strong>of</strong> 76SEATAC-400A key objective <strong>of</strong> this strategy was to receive fees from the IS0 for relieving congestion, withouthaving to provide any actual electricity at all. The IS0 charges congestion fees to partiesscheduling power in the congested direction, and pays those fees to parties scheduling power inthe opposite direction. The holders <strong>of</strong> existing transmission contracts are exempt from congestionfees. Therefore, when a scheduling coordinator schedules power in the congested direction usingthe system <strong>of</strong> an ETC holder, and simultaneously schedules power in the opposite direction on theISO's system, that scheduling coordinator will receive payments from the ISO, and will pay theIS0 nothing.Have you been able to identify instances in which Death Stars actually occurred?Some <strong>of</strong> the most valuable transmission contracts are held by the Los Angeles Department <strong>of</strong>Water and Power (LADWP). By comparing the information from LADWP's scheduling filesand the ISO's scheduling records, it is possible to match up transactions with <strong>of</strong>fsetting schedulesthat match this pr<strong>of</strong>ile.Can you describe the steps involved?Specifically, to find LADWP transactions that match the definition <strong>of</strong> a Death Star, I developed amapping from LADWP's definitions <strong>of</strong> tie-points to the ISO's definition. That made it possible tomatch imports on one system to exports on another. I also developed a mapping <strong>of</strong> the ISO'sabbreviations for scheduling coordinator to LADWP's codes for agents. This made it possible toidentify when the same party was scheduling power on both systems. I eliminated schedules for
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Page 77: CERTIFICATE OF SERVICEI hereby cert

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

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