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

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Page 6 <strong>of</strong> 76SE.4TAC-400the prices at which they would run. Such conduct was alsounreasonable under the circumstances.Generators wrongly assert that the IS0 had fill operational controlover the grid through RMR contracts andlor Automatic GenerationControl (AGC).'Q. What new evidence do we have <strong>of</strong> withholding in California?A. Reliant, AES, and Williams staff have been recorded in planning plant outages in order tomanipulate the market.Reliant Trader 2: What we are kinda thinking about doing right now is comingout and trying to buy 43. Buy dailies and then shut down all the plants and thenif it goes against us putting that, unwind hedges in the plant book.Reliant Manager 1: Yeah.Reliant Trader 2: And then that way we going to put out that we are short NOx,we're short capacity factor--or we're worried about the capacity factor <strong>of</strong>units, and trying to get people to say look we can't - these levels don't makesense to do. I mean at 88 bucks and just kinda urn.. ..then we can make theargument internally if we have to,Reliant Manager 1 : That it was a 21 buck margin.Reliant Trader 2: Yeah. I mean, we're down to 540.00 pr<strong>of</strong>it margin now'Supplement to the California Public Utilities Commission Staffs Wholesale Generator lnvestigatiion Report,September 17.2002, at 2 (SEATAC-701).
where as last week we were $70.00, and we'd rather unwind stuff and carryinto the summer.Reliant Manager 1: Yeah. And plus we'll use the deal we don't know whatOrmond's going to be doing and there's problems popping up.Page 7 <strong>of</strong> 76SEATAC-400Reliant Trader 2: Right. I mean, I feel more4 feel better about that than goingout and just coming out short when I think the market is going to rebound atsome point. Right now. But we're still talking about it right now.Reliant Manager 1: Well I was talking about the Q-the 2001.Reliant Trader 2: Well, yeah, I mean if it props up there and we're selling 2001.I mean we're doing this to prop up 2001 to sell into it2Later Reliant transcripts are even more explicit:Reliant Ops Manager 1: Yeah. That's probably the way to go if ya'll can swingit. If not, if we have to do it then I don't necessarily foresee those units being runthe remainder <strong>of</strong> this week. In fact you will probably see, in fact I know,tomorrow we will have all the units at Coolwater <strong>of</strong>f.Reliant Plant Operator 2: Really?Reliant Ops Manager 1: Potentially. Even number four. More due to somemarket manipulation attempts on our part. And so, on number four it probablywouldn't last long. It would probably be back on the next day, if not the day'Reliant Transcript, 6:30 A.M. June 20,2000, at I(SEATAC-48),
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