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

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Page 68 <strong>of</strong> 76SEATAC-400TACICAISO 2.2Please refer to the document entitled Analysis <strong>of</strong> Trading and SchedulingStrategies Described in Enron Memos, areport by CaliforniaISO Department<strong>of</strong> Market Analysis, dated October 4,2002, available on the ISO's website atwww.caiso.com (hereinafter "CAISO Report").(a) Please provide any information, studies, or analyses that the CAISOhas performed or that it has in its possession concerning congestionpayments to the entities listed in tables 2,6,7,9, 11, and 12 <strong>of</strong> theCAISO Report.(b) Please provide any information, studies, or analyses that the CAISOhas performed orthat it has inits possession concerning oversched~lling<strong>of</strong> power by entities listed in the CAISO Report, and the associatedeconomic impacts.(c) Please provide all studies the CAISO has performed regardingmanipulation or potential manipulation <strong>of</strong>markets in thenorthwesternUnited States andlor involvinguse <strong>of</strong>the AC Intertie by the entities listedin tables 2,6,7,9, 11, and 12 <strong>of</strong> the CAISO Report.(d) Please provide all workpapers used in creating the CAISO Report.
Page 69 <strong>of</strong> 76SE:ATAC-400Response:The IS0 objects to the entirety <strong>of</strong> question 2.2 because it seeksinformation that isnot relevant to theclaim or defense <strong>of</strong> any party, is notreasonably calculated to lead to the discove~y<strong>of</strong>admissiblevidence, andseeks data regarding activitiedparties that are not relevant to the subjectmatter <strong>of</strong> this proceeding.The October 4 Report deals with conditions in and analysis <strong>of</strong>' spotmarkets operated by the California ISO. Therefore, none <strong>of</strong> theinformation requested is relevant to claims "concemingpotential refundsfor spot market bilateralsales transactions in the Pacific Northwest forthe period January 1, 2000 through June 20,2001," December 19Discovery Order at P 1 (emphasis added), and isnot likely to lead to thediscovery <strong>of</strong> relevant information.Notwithstanding this objection, the IS0 notes that some information responsiveto this question has been provided by the IS0 in Docket Nos. EM2-113 (onDecember 16,2002 and February 4,2003), EL02- 114 (on November 4,2002and January 30,2OO3), and EL02-115 (on November 19,2002) in response todiscovery posed on the IS0 by the Commission Staff in each case.Respondent: Eric HildebrandtManager, Market Investigation
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