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

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Page 8 <strong>of</strong> 76SE.4TAC-400after that. Trying to uh ...Reliant Plant Operator 2: Trying to shorten the supply, uh? That way the priceon demand goes up.'And:Reliant Trader 1 : Yeah, we literally shut everything <strong>of</strong>f but hand.Everybody's like, you can't do that, and we're like, watch us. And it worked.Reliant Trader 3: Did the market find out?Reliant Trader 1: No, god no. They - somebody, you know, figured out.because they said that, came out in one <strong>of</strong> the rags that a non-utility generatorlooked like they were withholding generation. But, see we didn't because wereally bid it in. We just bid it in very high?Q. Do we have any other similar transcripts?A. Yes. FERC's investigation <strong>of</strong> Williams found similar transcripts:In particular, on April 27,2000, Ms. Morgan stated to an AES employee that,"if your Unit 4 outage runs long and if you need more time, we don't have aproblem with that" and "if you need more time, just let us know." Ms. Morganthen explained the reason Williams wanted the shutdown extended: because theIS0 was paying "a premium" for use <strong>of</strong> the non-RMR unit. She concluded that'Reliant Transcript, 8:25 A.M. June 20,2000, at 1 (SEATAC-48).'Reliant Transcript, 9:27 A.M. June 23,2000, at 3 (SEATAC-48).
Page 9 <strong>of</strong> 76SEATAC-400"that's one reason it wouldn't hurt Williams' feelings if the outage ran long ." Ms.Morgan then stated that if AES extended the outage, Williams "could pmbablygive [AES] a break on availability," apparently meaning that Williams would notcount Alamitos 4 as "unavailable" during the additional days <strong>of</strong> the outage . (AESis required under its operating contract with Williams, known as the TollingAgreement, to keep units available a minimum number <strong>of</strong> hours throughout thecontract year. Mr. White's request for repairs noted that Alamitos 4 was verylow on availability. Not counting as "unavailable" hours during which Alamitos 4would be <strong>of</strong>f-line during this outage would permit AES to declare Alamitos 4"unavailable" for a comparable period at another time.) Ms. Morgan thenadvised the AES employee that Williams would not give AES a cut <strong>of</strong> the pr<strong>of</strong>itWilliams would obtain h m the extension <strong>of</strong> the outage, just the "break" onavailability.Later that day, Eric Pendergraft, a high-ranking AES employee, followed up thisconversation, expressing his understanding that "you guys were saying That itmight not be such a bad thing if it took us a little while longer to do our work."Morgan responded by saying "we're not trying to talk yous [sic] into doin' it butit wouldn't hurt, you know, we wouldn't like throw a fit if it took any longer."Mr. Pendergraft responded: "Then you wouldn't hit us for availability?" Ms.Morgan agreed, adding "I don't wanna do something underhanded, but if there's
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CERTIFICATE OF SERVICEI hereby cert
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Prepared Direct Testimony of Robert McCullough on Behalf of the ...

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