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

Page 49 <strong>of</strong> 76SE.4TAC-400What they were not telling the IS0 was that at the same time, using LADWP's transmission rights,they were scheduling this same transaction in reverse. Table 2 shows hourly transactionsscheduled by Enron on the LADWP system."As we can see, Enron scheduled a wheelingtransaction for one hour (the hour ending at 12:OO noon) to import 24 MW at Malin, and to export24 MW at Mead. For each <strong>of</strong> the hours ending between 13:OO and midnight, they scheduled awheeling transaction to import 24 MW at Malin, and to export 24 MW at Palo Verde. In effect,they told LA they would bring 24 MW into California h m Oregon, ship it across the state, andexport it to Nevada and Arizona. This transaction exactly <strong>of</strong>fsets, hour by hour and MW by MW,the transaction they filed along the same paths at the ISO."LADWP Transaction Data, First Quarter 1997 through September 6,2001, Exhibit SEATAC424.