Staff/Gen-Tran-8

Referring to Exhibit GEN-1, page 12, line 20 to page 13, line 3, do you contend that making incremental heat rates monotonically non-decreasing produces lower heat rates?

Staff/Gen-Tran-9

Referring to Exhibit GEN-1, page 15, lines 19-21, please provide all workpapers and supporting documentation used to determine the 48% value.

Staff/Gen-Tran-10

Referring to Exhibit GEN-1, page 16, lines 9-10, please specify and briefly describe the third category of fuel costs.

Staff/Gen-Tran-11

Referring to Exhibit GEN-1, page 16, lines 16-18, please specify the intervals in which a marginal unit was running at its minimum load.

Staff/Gen-Tran-12

If a unit, which can operate at levels of 10-100 MW, runs at 100 MW in intervals of an hour, in which interval of that hour is it incurring minimum load costs?

Staff/Gen-Tran-13

Referring to Exhibit GEN-1, page 20, lines 6-7, please list each category of transactions not subject to refund that Mr. Tranen has excluded from his analysis.

Staff/Gen-Tran-14

Referring to Exhibit GEN-1, page 21, line 13, do you contend that "the units providing real-time energy to meet demand" includes units which were scheduled in the day-ahead market?

Staff/Gen-Tran-15

Referring to Exhibit GEN-1, page 21, line 13, do you contend that "the units providing real-time energy to meet demand" includes units which were selling energy under bilateral contracts?

Staff/Gen-Tran-16

Please refer to Exhibit GEN-1, page 23, lines 6-22 and  Exhibits GEN-11 and GEN-12.

a)	How were the net BEEP instructed energy volumes shown on Exhibit GEN-11 determined?  Include with your discussion what was netted in determining these volumes.

b)	How were the net non-BEEP instructed energy volumes shown on Exhibit GEN-11 determined?  Include with your discussion what was netted in determining these volumes.

c)	Please define “total system energy” as used on Exhibit GEN-11.  If "total system energy" is a net amount, please specify what was netted in determining these volumes.

d)	Does the chart shown on Exhibit GEN-12 show use "net" amounts (i.e., net BEEP instructed energy volumes as a percentage of net total system demand)?  If no, please explain what is plotted on this chart.

e)	Please define “total system energy” as used on Exhibit GEN-12.

f)	Do the negative percentages shown on Exhibit GEN-12 represent decremental energy?  If no, please explain.

Staff/Gen-Tran-17

Please refer to Exhibit GEN-13.

a)	Does the chart show net non-BEEP instructed energy volumes as a percentage of hourly total system energy?  If no, please explain what is plotted on this chart.

b)	It appears that  the note shown on Exhibit GEN-13 applies to BEEP rather than non-BEEP instructed energy.  Which is correct?  Please explain.

c)	Please list and describe the components of the non-BEEP instructed energy used to develop this chart and indicate its source.

d)	Please define “total system energy” as used on Exhibit GEN-13.

Staff/Gen-Tran-18

Referring to GEN-1, page 24, lines 8-11, do you contend that the IOUs were severely underscheduling their load after December 2000?  If so, what is the basis for your contention?

Staff/Gen-Tran-19

Referring to Exhibit GEN-1, page 26, lines 18-19, please provide all workpapers and supporting documentation used to determine the 40% value.

Staff/Gen-Tran-20

Referring to Exhibit GEN-1 page 31, line 6, do you contend that the Real Time Market is the same as the Day Ahead market?

Staff/Gen-Tran-21

Referring to Exhibit GEN-1 page 31, line 6, do you contend that the Real Time Market is the same as the Hour Ahead market?

Staff/Gen-Tran-22

Do you contend that units which have been schedule to their full capacity in the Day Ahead or Hour Ahead market are available for dispatch in the Real Time market?

Staff/Gen-Tran-23

Referring to Exhibit GEN-1 page 37, lines 1-15, do you contend that the ISO dispatches residual energy?

Staff/Gen-Tran-24

Please refer to Exhibit GEN-1, page 38, lines 4-11. 

a)	Please define "minimum run time", as used by Mr. Tranen.

b)	Does "minimum run time" differ from "ramp down time"?  Please explain.

c)	How did the California Generator Group identify those combustion turbine units that had a minimum run time of one hour?

d)	Please provide a list of those combustion turbines included in the California Generator Group's analysis that have a minimum runtime of one hour.

e)	Please provide an example of a combustion turbine that the California ISO instructed off before the end of its minimum run time and quantify the frequency of such occurrences.  Include all supporting workpapers.

f)	Please provide all supporting documents or analyses which demonstrate that the California ISO categorized combustion turbine energy as a combination of residual energy and uninstructed energy.

g)	Please provide an example of a combustion turbine whose minimum run time extended beyond the end of an hour (as discussed at lines 5-6) and was categorized as (i) Residual Energy; (ii) Uninstructed Energy.  In addition, quantify the frequency of such occurrences.  Include all supporting workpapers.

Staff/Gen-Tran-25

Referring to Exhibit GEN-1, page 38, lines 19-21, does Mr. Tranen have any documents that demonstrate that Category Nos. 11-15, as shown on Exhibit GEN-8, were used to provide general system energy?  If yes, please provide.  If no, what is the basis for Mr. Tranen’s statement that these units appear to have been used for general system energy?

Staff/Gen-Tran-26

Referring to Exhibit GEN-1, page 42, lines 19-23 and page 43, line 1, does Mr. Tranen contend that any transaction that is not subject to refund under the Commission’s July 25 Order should be excluded from determining the mitigated market clearing price?  Please explain and include any references to relevant Commission orders.

Staff/Gen-Tran-27

Referring to Exhibit GEN-1, page 44, lines 17-19, please describe “valid bid”, as used by Mr. Tranen.

Staff/Gen-Tran-28

Referring to Exhibit GEN-1, page 46, lines 14-19, 

a)	Please provide an actual example of the California Generator Group’s computation of a mitigated market clearing price determined for an interval that did not have any eligible units running in the real-time imbalance market.  Include with your response the step-by-step computation and indicate the method used for averaging.

b)	if the heat rates used in the surrounding intervals were from units located in the same region (e.g., North), did the California Generator Group consider using the gas prices from that region only, rather than applying an average of the North and South gas prices?  Please explain.

Staff/Gen-Tran-29

Referring to Exhibit GEN-1 page 49, lines 22-30, do you contend that the Commission directed use of a weighted average price?  If so, please identify the order and page number.

Staff/Gen-Tran-30

Referring to Exhibit GEN-1, page 50, lines 6-10, please provide an example demonstrating the step-by-step application of California Generator Group’s method for calculating the hourly mitigated market clearing price.  Please use an actual MMCP developed by the California Generator Group as your example.

Staff/Gen-Tran-31

Referring to Exhibit GEN-1, page 53, lines 20-22 and page 54, lines 1-11, please explain, in detail, how applying the mitigated market clearing price as a cap rather than a new market price necessitates a change in the universe of units used to determine the mitigated market clearing price.