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

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Page 58 <strong>of</strong> 76SE:ATAC-400Figure 2: Example HalfDeath Star ~ransactions~~2 Q. Did you find examples <strong>of</strong> this type <strong>of</strong> transaction as well?3 A. Yes. For example, on June 17,2000, during the hour ending at 5:00 PM, Enron scheduled an4 export <strong>of</strong> 50 MW at Malin on the IS0 syst~m.~' For the same hour, PGE scheduled an import <strong>of</strong>5 50MW at Malin on the LA system.526 In addition to the example above, it is not even necessary for the amount <strong>of</strong> power scheduled in7 each direction to match. For example, if the scheduling coordinator schedules 50 MW in one8 direction and 30 MW in the other, this can be considered a 30 MW half Death Star.SoSchernes Death Star Workpapers, Exhibit SEATAC-426."LADWP All Schedules and Prices 2000.csv and All Schedules & Prices for 1-1-2001 to 9-6-2001 .csv,Exhibit SEATAC424; CAISO Transaction Data, Third Quarter 1998 through Third Quarter 2002, Exhibit SEATAC-425."Id.
Page 59 <strong>of</strong> 76SElATAC-400Q. Is this the only example <strong>of</strong> a half Death Star you found?A. No, actually we found tens <strong>of</strong> thousands, looking at the period between January 1,2000 andSeptember 6, 2001.5' Table 6 provides the number <strong>of</strong> matching transactions we detected justlooking at some <strong>of</strong> the parties named in various FERC investigations. The number <strong>of</strong> transactionsgiven here represents the hour-ahead schedules at a given tie point, date, and hour matching thedescription <strong>of</strong> a half Death Star provided above. Given that the universe <strong>of</strong> Death Stars are solarge, we could have taken a much longer list <strong>of</strong> scheduling coordinators than these. This list wasbased on the major generators and several other major market participants.Table 6: HalfDeath Star Transactions for Selected Scheduling Coordinatorss'................... . . ................Enmn..........................Q. Can you provide an example <strong>of</strong> how AEP filed schedules that match the description <strong>of</strong>a half Death Star?A. Yes. We found over 1000 tie-point-hours <strong>of</strong> such transa~tions.~' On July 21,2000, AEP- -"Id.%themes Death Star Workpapers, Exhibit SEATAC-426."LADWP All Schedules and Prices 2OOO.csv and All Schedules & Prices for 1-1-2001 to 9-6-2001 .csv,Exhibit SEATAC-424; CAISO Transaction Data, Third Quarter 1998 through Third Quarter 2002, Exhibit SEATAC-425.
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