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

summarizes their conclusions as:The IS0 and the Commission staff agree on a number <strong>of</strong> crucialsubstantive points, namely:Generators did not bid all their capacity into the ISO's markets. Thisin turn forced the IS0 to fmd and procure resources in "real time" (thatis, under pressure at the last minute) in order to serve load.Generators did not follow dispatch instructions. Those failures t<strong>of</strong>ollow dispatch instructions during system emergencies imperiled thesystem and the provision <strong>of</strong> reliable electrical service to the State.Generators declined Automatic Dispatch System instructions, citing"economic considerations," conduct which was not reasonable under thecircumstances. By Commission staffs count, generators refused in thisway to increase power production 311 times (even ignoring dispatchesfor less than 5 megawatts) because the IS0 tried to dispatch many bidsmultiple times during a particular hour. (Meanwhile, in the same period,generators did not respond to the IS0 instructions for 5 megawatts ormore <strong>of</strong> power 1623 times. More than a third <strong>of</strong> these 1623 instructionswere IS0 requests for 50 or more megawatts <strong>of</strong> power.The IS0 encountered circumstances where generators refused to run,citing lack <strong>of</strong> operating personnel, or argued with IS0 operators over