Media

McCullough Research has appeared in industry journals and the mainstream media. Please contact the publication listed for permission to reproduce or distribute the items below.

2000, 2001, 2002, 2003, 2004, 2005, 2006, 2007, 2008, 2009, 2010, 2011, 2012, 2013, 2014, 2015, 2016, 2017

2020

How a Florida Power Project Flew Under the Regulatory Radar

“We have 120 years of crazy regulatory practice in electricity and natural gas,” Mr. McCullough said. “There will be a day when someone will ask why they have just an extension cord there instead of the appropriate transmission line, because none of this makes good economics or engineering sense.”

California is beginning to bury its power lines to prevent wildfire

Compared to elsewhere, PG&E has been slow to embrace the solution, said Robert McCullough, a veteran energy consultant in Portland, Oregon, and adjunct professor of economics at Portland State University.

“California is the nation’s most regulated state, with a certain amount of inertia. It’s rigid and slow to respond,” he said. “But Pacific Gas & Electric is the posterchild child of rigidity… It should have been fixing everything all the time.”

Dems turn to the FTC to crack down on gas-price hikes

Some industry experts say the FTC is ill-equipped to properly surveil the full breadth of petroleum markets, from crude transactions to refining and trading to gas-station retail. Robert McCullough, an economist who consults with committee members and helped blow the whistle on Enron electricity-price gaming two decades ago, is backing the Democratic push.
“We do not actually have market surveillance of gasoline or oil in the United States, except to the degree that the [Commodity Futures Trading Commission] might notice something happening in the forward market,” McCullough said in an interview.

Blumenthal Calls for More Federal Action to Lower Gas Prices

Senator Blumenthal, I agree very deeply. Number one, tax incidents goes entirely to consumers. There’s a lot of academic research on that so 100 percent of your gas tax cut goes right to consumers. Number two, if we’re going to get the best benefit out of the Strategic Reserve, the best thing we could do is to replace the Strategic Reserves by purchasing forward. That gives direct financing to little guys because little guys don’t necessarily get to go to the Chase Manhattan Bank, they can sell their future production on the foreign curve in order to drill now. And number three, the fact of the matter is that we need to have a windfall tax that does not injure product. I put a formula in my testimony here, I’m not sure it’s the best, but there are ways to structure the windfall tax to give an incentive to start drilling now.

Opinion: Congress plays the blame game on gas prices

The Atlanta Journal-Constitution – Jamie Dupree
“Why the gas price doesn’t follow the oil price down in Georgia is something we really do need to get to the bottom of,” energy research expert Robert McCullough testified, as he joined Warnock in urging the Federal Trade Commission to investigate.
“Some of the increase is due obviously to Putin’s war,” McCullough added. “But other increases are inexplicable at the moment.”

Feinstein Joins Cantwell, Wyden in Calling for Investigation of West Coast Gas Prices

Senate.gov – Diane Feinstein

According to the April 5, 2022, testimony of Robert F. McCullough, Jr. before the Senate Commerce Committee, certain benchmark indices are used to price petroleum contracts across the West Coast market. These indices are based on transactions that are not on an exchange, not public, and not well understood.

Cantwell mulls Enron-like transparency mandates for petroleum

E&E News – Jeremy Dillon

“There is, however, one gaping hole,” said Robert McCullough, a principal with McCullough Research, who helped uncover the Enron scandal. “That gaping hole is spot oil, spot gasoline, those do not have a clear assignment.”

2017

July 20, 2017 Portland on track to pay $8 million for hydroelectric plant operations with risk of losses Oregonian, Jessica Floum

“If PGE purchases the same amount of power next year that it has over the last four years at the rate that McCullough says wholesale power buyers are paying in the coming year, Portland will lose $300,000 next year.’It’s unlikely the city of Portland will make out like bandits because PGE will have many options,’ McCullough said at the time.”

July 7, 2017 Elon Musk said Tesla could build Australia a power storage system in 100 days LA Times, Makeda Easter

“Although Musk is known for his ability to hype his products, his pledge isn’t so far-fetched,’ said Robert McCullough, an energy consultant who runs Oregon-based McCullough Research.”

June 28, 2017 Law firm recommends NextEra to provide city’s electricity Pharos-Tribune, Mitchell Kirk

“Logansport Mayor Dave Kitchell asked the utility service board at Tuesday’s meeting to move to provide the city’s law department, made up of City Attorney Yamir Gonzalez-Velez and LMU Attorney Jim Brugh, with the three finalist proposals Lewis & Kappes was considering. He also asked that that information be passed along to McCullough Research, a utilities consulting firm out of Portland, Oregon that the city’s board of public works and safety hired in April.”

June 23, 2017 It was hot this week. But were California officials ‘crying wolf’ with alerts that drove up electricity prices? Los Angeles Times, Ivan Penn

“’The notion that the sky is falling is a little bewildering to us,’ said Robert McCullough, of Oregon-based McCullough Research, who works as a consultant for power companies.”

June 22, 2017 Why Californians don’t have to worry about their air conditioning conking out Sacramento Bee, Dale Kasler

“There’s nothing particularly wrong with having too much capacity, except the ratepayer has to pay for it,’ said Robert McCullough of McCullough Research, an energy consulting firm in Portland. But he added: ‘Generally, ratepayers are willing to pay for a very reliable system.”

June 16, 2017 Privatizing Grid a Bad Idea, McCullough Report Says. Clearing UP, Rick Adair

“Economist Robert McCullough has put numbers to the regional pushback against the Trump administration’s May 23 budget proposal to sell BPA’s grid, which he says greatly undervalues the system, would increase costs for consumers and would likely raise steep regulatory hurdles.”

June 15, 2017 Trump sale of Northwest grid a big loser, experts say The Oregonian, Ted Sickinger

“Robert McCullough, an energy economist in Portland, called the figure ‘an unheard of low price’ that any company with the resources would snap up immediately. He said they would make a particularly attractive acquisition for Warren Buffet, whose Berkshire Hathaway Energy owns PacifiCorp and NV Energy in Nevada. PacifiCorp, like Bonneville, is a big player in the western transmission market. ‘Why would they discount it below minimum market price out of the shoot?’ he asked. ‘Has the negotiation already happened?’ ‘If it was any other president I wouldn’t fall into this conspiracy,’ he added.”

June 14, 2017 Cantwell Statement On Privatization Of Bonneville Power Administrations Transmission Assets Bakhtar News Agency, BAKHNA

“A June 13 report from McCullough Research said proposed revenues from the sale of BPA’s transmission assets are only 80% of the value of the assets being sold.”

June 14, 2017 Selling BPA assets seen as detrimental to ratepayers SNL Energy Finance Daily, Kelly Andrejasich

“Today, Ranking Member of the Senate Energy and Natural Resources Committee Maria Cantwell (D-Wash.) responded to the report released today by McCullough Research on the privatization of Bonneville Power Administration’s transmission assets.”

June 13, 2017 Cantwell Statement On Privatization Of Bonneville Power Administration’s Transmission Assets US Senate Committee on Energy and Natural Resources, Democratic News

Responding to Robert McCullough’s report on the proposal to sell the Bonneville Power Administration’s transmission assets, US Senator Maria Cantwell said: “This report shows how damaging President Trump’s proposal is to the Northwest. Any scheme to auction off the transmission assets of federal utilities, such as the Bonneville Power Administration, is a bad deal for consumers and for jobs in the Northwest.”

June 12, 2017 Trump Fights Congress, History in Bid to Sell Tx Assets RTO Insider, Jason Fordney and Robert Mullin

“Portland-based energy economist Robert McCullough estimates that the budget’s proposed $4.9 billion in revenues from the sale of Bonneville’s transmission network represents just 80% of the value of those assets, based on the power agency’s own published estimates. ‘This raises the question of why these valuable assets would be sold at a discount — and who would get the benefit of the discounted price,’ McCullough Research said in a June 13 report.”

May 3, 2017 Large-Scale Solar Power Is Spreading Across the U.S. Green Building Advisor, Guest Blogs

“In the past couple of years, McCullough said, cost shifts have been so astonishing that ‘now we have really quite a revolution going on… The scary thing is you’ve now heard this from a cynic.’”

March 23, 2017 Northern Lights: Large-Scale Solar Power Is Spreading Across the U.S. Yale Environment 360, Cheryl Katz

“’I’d been hearing that all of this is just around the corner, and then one day it was staring me in the face,’ says McCullough, principal of the Oregon-based industry consulting firm McCullough Research.”

March 10, 2017 Elon Musk’s wager that Tesla can fix South Australia’s blackouts brings the energy future closer The Los Angeles Times, Samantha Masunaga and Ivan Penn

“’I would say, ‘Not yet, but getting close,’’ said Robert McCullough, an energy consultant who runs Oregon-based McCullough Research. Storage is still too expensive, but multiple companies are competing to push the price lower, he said.”

February 28, 2017 Guest Commentary: There’s a nuclear reactor in my backyard Chinook Observer, Leslie March

“The Portland-based McCullough Research consulting firm estimated savings from $261.2 million to $530.7 million over 10 years”

February 27, 2017 Study: Shutting Nuclear Plant Would Save Upward of $261M Federal Briefs, RTO Insider

“Pacific Northwest ratepayers could save hundreds of millions of dollars if the Bonneville Power Administration and Energy Northwest were to close the Columbia Generating Station and replace its output with renewable energy, according to a new study by McCullough Research.”

February 24, 2017 Report claims closing Wash. nuke could save more than $500M SNL Extra, Kelly Andrejasich

“McCullough Research suggests that closing the plant — as soon as this year — could save Pacific Northwest ratepayers $261.2 million to $530.7 million over a roughly 10-year period.”

February 23, 2017 Whoops! Newsletter, EnergyGPS

“[T]he most compellingargument made by this report is that the ongoing cost of running the CGS is well above the forward market price of around-the-clock power.”

February 23, 2017 Study: Replacing nuclear power with renewable energy could save Northwest ratepayers over $260 million The Register-Guard, Associated Press

“’The rapid drop in renewable energy costs in recent years has been shocking to everyone,’ economist Robert McCullough said. ‘It is now possible to affordably replace aging facilities … without increasing the region’s carbon footprint.’”

February 22, 2017 Firm finds Columbia Generating Station closure would save money Electric Light and Power, Associated Press

“’The rapid drop in renewable energy costs in recent years has been shocking to everyone,’ economist Robert McCullough said. ‘It is now possible to affordably replace aging facilities … without increasing the region’s carbon footprint.’”

February 22, 2017 Study: Savings possible by shutting down nuclear power plant Penn Energy, Associated Press

“’The rapid drop in renewable energy costs in recent years has been shocking to everyone,’ economist Robert McCullough said. ‘It is now possible to affordably replace aging facilities … without increasing the region’s carbon footprint.’”

February 22, 2017 Study: Savings possible by shutting down nuclear power plant The Daily Astorian, Associated Press

“Portland-based McCullough Research consulting firm estimated savings from $261.2 million to $530.7 million over 10 years due to historically low renewable energy prices.”

February 21, 2017 Study: Savings possible by shutting down nuclear power plant San Antonio Express, Associated Press

“’The rapid drop in renewable energy costs in recent years has been shocking to everyone,’ said economist Robert McCullough. ‘It is now possible to affordably replace aging facilities … without increasing the region’s carbon footprint.'”

February 21, 2017 Study: Savings possible by shutting down WA nuclear power plant Statesman Journal, Associated Press

“Portland-based McCullough Research consulting firm estimated savings from $261.2 million to $530.7 million over 10 years due to historically l0w renewable energy prices.”

February 21, 2017 Study: Savings possible by shutting down nuclear power plant Idaho Statesman, Associated Press

“‘The rapid drop in renewable energy costs in recent years has been shocking to everyone,’ said economist Robert McCullough. ‘It is now possible to affordably replace aging facilities … without increasing the region’s carbon footprint.'”

February 21, 2017 Study: Savings Possible by Shutting Down Nuclear Power Plant U.S. News, Associated Press

“Portland-based McCullough Research consulting firm estimated savings from $261.2 million to $530.7 million over 10 years due to historically low renewable energy prices.”

February 21, 2017 Study: Savings possible by shutting down nuclear power plant New Jersey Herald, Associated Press

“’The rapid drop in renewable energy costs in recent years has been shocking to everyone,’ economist Robert McCullough said. ‘It is now possible to affordably replace aging facilities … without increasing the region’s carbon footprint.’”

February 21, 2017 Report: Shutting Columbia Generating Station nuclear facility could save millions The Spokesman-Review, Associated Press

“’The rapid drop in renewable energy costs in recent years has been shocking to everyone,’ economist Robert McCullough said. ‘It is now possible to affordably replace aging facilities … without increasing the region’s carbon footprint.’”

February 21, 2017 Study: Savings possible by shutting down nuclear power plant SFGATE, Associated Press

“’The rapid drop in renewable energy costs in recent years has been shocking to everyone,’ economist Robert McCullough said. ‘It is now possible to affordably replace aging facilities … without increasing the region’s carbon footprint.’”

February 21, 2017 Study: Savings possible by shutting down nuclear power plant The Seattle Times, Associated Press

“’The rapid drop in renewable energy costs in recent years has been shocking to everyone,’ economist Robert McCullough said. ‘It is now possible to affordably replace aging facilities … without increasing the region’s carbon footprint.’”

February 18, 2017 Closing Richland Nuclear Plant Would be a Win for Ratepayers, Study Says The Oregonian, Ted Sickinger

“‘The rapid drop in renewable energy costs in recent years has been shocking to everyone,’ said economist Robert McCullough. ‘It is now possible to affordably replace aging facilities, like the 32-year old [Columbia Generating Station] … without increasing the region’s carbon footprint.'”

February 5, 2017 Californians are Paying Billions for Power They Don’t Need Los Angeles Times, Ivan Penn, Ryan Menezes

“Critics agree that some excess capacity is needed. And, in fact, [California] regulations require a 15% cushion. […] Even the 15% goal is ‘pretty rich,’ said Robert McCullough of Oregon-based McCullough Research, who has studied California’s excess electric capacity for both utilities and regulators. ‘Traditionally, 10% is just fine. Below 7% is white knuckle. We are a long way from white-knuckle time’ in California.”

2016

December 14, 2016 Eversource, Dong Energy Eye Wind Farm Project New Haven Register, Luther Turmelle

“McCullough said his prediction that Bay State Wind may be dead in the water before it even starts has more to do with economics than it does with the utility company’s track record. ‘Off-shore wind is a particularly bad choice for renewable generation given the rapidly diminishing costs of on shore wind and solar,’ he said. ‘These have fallen in price by 40 percent over the last five years. Like LED light bulbs, economies of scale are driving down the delivered cost.'”

November 3, 2016 Consultant: Logansport’s Power Agreement Could Have Been Better Logansport Pharos-Tribune, Mitchell Kirk

“McCullough said NextEra Energy Power Marketing’s price increased during the negotiations that followed with local officials and that the firm’s rate to LMU is higher than rates reported to the Federal Energy Regulatory Commission for its two other Indiana clients.”

October 11, 2016 Halting Construction of Site C Could Save $112-million Annually, Says Energy Expert DeSmog Canada, Judith Lavoie

“As the cost of producing energy from wind and sun continues to drop, power produced by the Site C dam will be an increasingly bad bargain, according to leading U.S. energy economist Robert McCullough.”

August 31, 2016 CPUC Reform Legislation Still In Play For California’s Governor Natural Gas Intelligence, Richard Nemec

“Oregon-based utility consultant Robert McCullough argues for no ex parte communications being allowed, noting that the amounts of money and potential for abuse in most major utility regulatory cases are too great.”

August 29, 2016 Even After Reforms, the State’s Energy Regulator can Still have Private Meetings with Utility Companies Los Angeles Times, Liam Dillon

“Robert McCullough, a consultant who investigated the state energy system during the Enron Corp. scandal in 2001, argued there shouldn’t be any private communications between regulators and the industry when they’re deciding electric and gas rates for consumers. ‘The amounts of money are so huge and the potential for abuse is so great that even just a pinkie on the scale can mean millions or tens of millions [of dollars],’ McCullough said.”

August 11, 2016 Upholding Treaty Rights for First Nations Penticton Western News, Richard Cannings

“BC citizens would benefit financially from a go-slow policy around site C; energy economist Robert McCullough has calculated that a one-year delay in construction would save us $268 million because of the current low demand for power.”

August 4, 2016 Site Unseen Pique, Leslie Anthony

“American energy economist Robert McCullough calculated that a delay of one-year would save ratepayers $268 million, two-years, $519 million, and five-years, $1.18 billion.”

June 22, 2016 Tesla’s bid for SolarCity would bring two Elon Musk companies together Los Angeles Times, Russ Mitchell and Ivan Penn

“McCullough said it appeared that Musk was doubling down on solar at a time when the economics of solar installations has been called into question. Solar, he said, has become so cheap that it’s becoming difficult to make money, as the industry learned with SunEdison, which went bankrupt in April. ‘These guys are victims of their own success,’ McCullough said.”

May 9, 2016 Why a SoCal Gas exec is more optimistic about avoiding summer blackouts in L.A. Los Angeles Times, Ivan Penn

“‘The system was built with the existing storage in place’ at Aliso Canyon, said McCullough, who heads McCullough Research of Portland, Ore. ‘Everybody depended on it. What we are now seeing is full system testing, where you have to test the whole system to see what works and what doesn’t.'”

April 25, 2016 Partner in Beaverton solar project declares bankruptcy The Oregonian, Allan Brettman

“McCullough said the project is not cost effective and never will be. Now, he said, Beaverton should exercise its contractual option to leave the project in the event of a bankruptcy declaration.”

February 17, 2016 BC Hydro Injunction Against Site C Dam Encampment ‘Fundamentally Flawed’: Former CEO Marc Eliesen DeSmog Canada, Sara Cox

“U.S. energy economist Robert McCullough testifies that a one-year delay in construction would save B.C. ratepayers $268 million, a two-year delay would save $519 million, and a five-year delay would result in net savings of $1.18 billion. McCullough says savings result from Site C power sold at a loss due to a ‘dramatic fall in world energy prices since 2008.’”

February 16, 2016 Stalled power outlook not slowing Site C dam Alaska Highway News, Timothy Renshaw

“Robert McCullough, principal of energy policy research company McCullough Research, said the horizontal hydraulic fracking revolution has rendered Site C ‘an expensive luxury’ in a world where the price of natural gas is roughly one-third of what it was in 2008.”

January 28, 2016 Site C: Too risky to rely on one river system for B.C.’s hyrdro needs The Vancouver Sun, Ben Paritt

“Using industry standard assumptions, Site C is more than three times as costly as the least expensive option,” McCullough said. “Site C fares poorly when compared to cogeneration, wind, landfill and coal gasification.”

January 4, 2016 Feds rule downstate power price spike illegitimate Crain’s Chicago Business, Steve Daniels

The Federal Energy Regulatory Commission sided with Illinois Attorney General and McCullough Research client Lisa Madigan when it ruled that MISO inappropriately set the price ceiling too high in its capacity auction, vindicating reports and testimony by McCullough Research that MISO’s market rules led to price spikes in the region.

See also: Robert McCullough’s testimony to the Federal Energy Regulatory Commission on behalf of Illinois Attorney General Lisa Madigan FERC order 20151231-3026 on MISO market manipulation under docket EL15-70 et. al

2015

October 29, 2015 NYPSC spurns legislator’s request for generator data in N.Y. wholesale market Electricity Daily

“Consultant Robert McCullough, whose affidavit supporting Brennan’s request made clear the ease by which one generator could obtain information on the others’ costs, told Electricity Daily, ‘New York has one of the most distorted electric markets in the world, with 8% of all bid segments over $500/MWh.’ He added, ‘I think the appropriate quote is, “Pay no attention to that man behind the curtain—the Great Wizard of Oz has thundered his advice.”‘”

October 7, 2015 Should bidding data in power markets be available and transparent, or secret? Electricity Daily

“‘Transparency is a necessary component of competitive markets,’ McCullough argues. ‘New York has traditionally been an outlier among administered electric markets. Although bizarre and inexplicable bids — those where prices per MWh wildly exceed any conceivable level of marginal cost — occur in most administered markets, New York has had an unusually high share of such aberrations.'”

September 8, 2015 How governments enable companies to distort prices Al Jazeera, David Cay Johnston

“McCullough observed that ‘the secret filings required to keep secret the secret bids were not secret, since they were available on Google and, after all, the bids themselves could be decoded by a barely competent ten year old.’ He then mused about whether the state would soon be ’rounding up all of the barely competent ten year olds in New York’ to keep secret the non-secrets of electric power plant heat rates.”

September 2, 2015 New York’s electricity market is a scam Al Jazeera, David Cay Johnston

“McCullough devoted six pages to examples of what Potkin told regulators must be kept secret but that Entergy publishes in various places. McCullough then went on for page after page showing how other companies making similar claims either publish the data or how ‘any reasonably competent analyst’ can distill the facts from a host of published reports.”

August 14, 2015 Keller Rohrback Investigates Alleged Price-Fixing by Chevron, Exxon, BP, and Other Major Oil Refiners on the West Coast Business Wire

“McCullough Research found that sudden price shifts have created a ‘windfall’ for West Coast refineries.”

August 6, 2015 PUC hit with fresh criticisms over dealings with Edison Los Angeles Times, Ivan Penn

“Robert McCullough, an energy industry consultant who analyzed Peevey’s emails with PG&E executives and others, said shortly after the messages were publicly released that ‘Peevey has passed beyond’ improper contacts with PG&E.”

July 27, 2015 Illinois Attorney General Joins Call for Changes to MISO Auction Rules RTO Insider, Chris O’Malley

“Citing FERC’s Electric Quarterly Reports, consultant Robert McCullough, a witness for the state, said that prices of the few bilateral sales from MISO to PJM were low — with one at only $1.09/MW-day.”

July 27, 2015 BCGEU stands with First Nations to oppose Site C dam National Union of Public and General Employees

“Robert McCullough reports that the dam would cost twice as much as alternative energy options like renewables and natural gas generation.”

July 13, 2015 Gasoline Prices Surge in California, Retreat in Rest of the Country AllGov, Ken Broder

“A lawsuit cites a spike in 2012 when supply was high, demand was low and inventories were increasing, yet the price of gasoline still rose. McCullough Research likens the suspicious market behavior to a similar oil bubble in 2008.”

June 18, 2015 Voice of BC Interview with Robert McCullough and Rob Botterell Voice of BC

“Our ability to forecast the costs of these mega-projects has always been poor. These are hard projects to predict. Almost every one of them has had a cost overrun in the past. But the delay issue is pretty simple. Natural gas got so cheap that the price along the entire West Coast is now down to approximately $30/MW-h. That’s almost a third of the cost of Site C. If you change some of the assumptions – bring them up to date – it’s an even smaller fraction. What that means is that bringing Site C into play now means we’re going to be selling $80-90/MW-h power for $30. It’s very hard to make a profit like that.”

video

June 3, 2015 Rigged electricity market strikes Illinois Al Jazeera, David Cay Johnston

“A pivotal supplier is effectively equivalent to a monopolist,” McCullough writes. “Since the market cannot clear without its participation, it can set whatever price it chooses.”

May 27, 2015 James: Site C concerns intertwine with other issues North Shore News, Elizabeth James

“Speaking at a recent Peace Valley Landowner Association event, respected energy economist Robert McCullough summarized his report on the dam: ‘Using BC Hydro’s assumptions, the difference in cost between the least expensive option and Site C is minimized,’ he said. ‘Using industry standard assumptions, Site C is more than three times as costly as the least expensive option.'”

May 27, 2015 ‘Fatal flaws’ in business case for Site C, says landowners association Alaska Highway News, Mike Carter

“McCullough pointed to several “fatal flaws” which show BC Hydro’s business case for the dam was skewed to favour Site C over alternatives. Delaying construction by at least two years would also save ratepayers $200 million, the report claims.”

May 26, 2015 Power from Site C dam ‘dramatically’ more costly than thought: expert The Globe and Mail, Justine Hunter

“Mr. McCullough, in his report, said it appears the Crown corporation BC Hydro had its thumbs on the scale to make its mega project look better than the private-sector alternatives…McCullough, a leading expert on power utilities in the Pacific Northwest, also disputes the rate that BC Hydro used to compare the long-term borrowing cost of capital for Site C against other projects, noting that other major utilities in North America use higher rates for such projects because they are considered risky investments.”

May 26, 2015 Economist challenges business case for Site C dam The Vancouver Sun, Gerry Bellett

“Robert McCullough, who was commissioned by the association to study the Site C business case, challenged cost assumptions being used as a basis for the decision to build the dam. There is evidence suggesting that “BC Hydro’s choice of a discount rate may have differed from their usual practice,” he said Tuesday in Vancouver.”

May 26, 2015 Damning report for Site C dam Business in Vancouver, Nelson Bennett

“McCullough’s report on Site C blows holes in some of the fundamental assumptions BC Hydro, the B.C. government and a joint review panel worked from to conclude that Site C dam is the cost effective means of generating power in B.C.”

May 26, 2015 PVLA says Hydro should delay the Site C project by two years EnergeticCity.ca, Tania Finch

“‘Using BC Hydro’s assumptions,’ said McCullough in his report, ‘the difference in cost between the least expensive option and Site C is minimized. Using industry standard assumptions, Site C is more than three times as costly as the least expensive option.'”

April 27, 2015 Portland economist says region’s last nuke losing $250 million on fuel deal Willamette Week, Nigel Jaquiss

“McCullough, a former Portland General Electric executive who consults for utilities and other clients all over North America, examined the economics of the plant, rather than safety issues. He found that the aging nuke plant is less cost-effective than other forms of generation. He was particularly critical of the long-term fuel purchase the utility made, based in part on what he found were unrealistic assumptions about financing costs.”

April 22, 2015 Drinks, dinners, favors helped PG&E lobbyist build PUC ties, emails show Los Angeles Times, Marc Lifsher

“Cherry was exceedingly effective, said Robert McCullough, a Portland, Ore.,energy consultant and expert witness in the Enron Corp. scandal investigation in 2001. ‘He was a hell of a salesman,’ McCullough said.”

April 8, 2015 Shell-BG deal could fuel more oil and gas industry consolidation Los Angeles Times, Tiffany Hsu

“‘These larger and larger dinosaurs are combining so they have more market power and a better chance at controlling price and output,’ said Robert McCullough Jr., managing partner at Oregon energy consulting firm McCullough Research. […] ‘In the short run, we don’t see this as a problem,’ McCullough said. ‘But bigger doesn’t seem to be better — market concentration is not our friend.'”

March 31, 2015 Why gas prices in California are so much higher than elsewhere in U.S. Los Angeles Times, Tiffany Hsu

“‘It is cost effective for companies in very concentrated industries to allow one to set the price and have everyone else follow along,’ said Robert McCullough Jr., managing partner at the firm. ‘It’s not necessarily unethical. It’s not even illegal. It’s just inefficient and not good for the U.S. economy.'”

March 3, 2015 Oregon Gas Prices: Why have they jumped 70 cents a gallon in a month? The Oregonian, Joseph Rose

“Even as gas prices collapsed late last year, they didn’t drop as far as they probably should have in the Northwest, McCullough said. He said he is still analyzing price and revenue trends to look at whether refinery operators have been manipulating prices to increase profits.”

February 27, 2015 Emails show PG&E helped PUC official write safety directive Los Angeles Times, Marc Lifsher

“Energy consultant Robert McCullough, who has analyzed thousands of emails that PG&E gave the commission, said he was put off by the continuous banter among PUC and utility officials. The emails show an “unacceptable level of influence” by PG&E with regulators, he said.”

February 27, 2015 Financiers and power producers rig electricity markets Al Jazeera, David Cay Johnston

“Robert McCullough, an Oregon utility economist known for busting industry myths, says gaming of electricity markets is easy and lucrative, as long as regulators look the other way. […] ‘Clearly, the story is that you could not buy the other New England power plants unless you committed to Brayton Point’s closure,’ he explained. ‘This is part of the nudge, nudge, wink, wink of mergers and acquisitions’.”

February 3, 2015 PUC emails appear to show former chief Michael Peevey overstepping his role Los Angeles Times, Marc Lifsher

“The bottom line is that I am amazed,” said Robert McCullough, an energy industry consultant and a former longtime manager at Portland General Electric in Oregon, who has analyzed thousands of the emails. “Peevey has passed beyond” improper contacts with PG&E, McCullough said, and took on a “role where he was commenting and recommending promotions at PG&E.”

2014

August 12, 2014 Assemblyman fights generator owners for disclosure Capital New York, David Giambusso

“He cited a report commissioned by his predecessor on the committee, then-Assemblyman Richard Brodsky, which alleged in 2009 that power generators overcharged customers by $2.2 billion. The report was prepared by energy expert Robert McCullough.”

June 11, 2014 Murmurs: We Hate Coal. We Love Coal. (We Can’t Decide.) Willamette Week, Editorial Staff

“Portland energy economist Robert McCullough, who panned the fuel deal, says the GAO [U.S. Government Accountability Office] report vindicates his findings. ‘The takeaway is the GAO says the transactions were illegal and resulted in ratepayers paying far too much for fuel they didn’t need,’ McCullough says.”

June 9, 2014 Report says DOE lacked authority to give Energy Northwest depleted uranium Tri-City Herald, Annette Cary

“McCullough Research, a Portland energy consulting firm, has questioned whether Energy Northwest used an unusually low discount rate, one lower than inflation, to value its payments from the Tennessee Valley Authority. Robert McCullough has said that Energy Northwest paid more than the market price for the uranium and that the price has since fallen.”

June 4, 2014 Coal-Line Stand Willamette Week, Nigel Jaquiss

“‘It will decrease the price of U.S. coal even further,’ says Portland energy economist Robert McCullough. ‘We feel good because we are closing coal plants here, but the same coal may end up in a Third World country where the plants are inefficient and poorly run.’”

June 3, 2014 With carbon rule, Illinois power struggle begins Chicago Tribune, Julie Wernau

“Robert McCullough, managing partner at McCullough Research in Portland, Ore., said a carbon rule won’t solve all of Exelon’s problems.

‘The downward pressure on prices comes from inexpensive natural gas and zero marginal cost renewables,’ McCullough said.”

April 30, 2014 WHOOPS! Nuke Presentations on Tap as Power Council Comes to Boise Snake River Alliance, Ken Miller

“McCullough’s report for Physicians for Social Responsibility portrays the Columbia Generating Station as an economic disaster. According to its analysis, the Bonneville Power Administration paid $419 million to run the plant in 2013, while it could have secured the same amount of energy elsewhere for about $219 million. The difference of $200 million-plus could have reduced BPA rates by more than 10 percent, McCullough’s report notes.”

April 26, 2014 Public records request no longer budget buster for Energy Northwest Tri-City Herald, Annette Cary

“Collaboration between Energy Northwest and McCullough Research has narrowed the Portland company’s potentially budget-busting public records request.

McCullough Research officials said they were not aware of estimated cost for processing the records until contacted by the Herald after a March meeting of the Energy Northwest Executive Board. An initial electronics records search showed as many as 155,000 documents, including drafts and emails, that touched on the Paducah deal. But McCullough Research agreed this month that only documents in the first five months of 2012 were needed, and only those that involved eight key people. The search also was narrowed to documents that included key words such as ‘Paducah’ and ‘uranium tails.'”

April 21, 2014 Nuclear debate on Clark Public Utilities agenda: Economist’s study finds power plant is a waste of money The Columbian, Aaron Corvin

“The Columbia facility, in operation since 1984, costs Northwest ratepayers on average as much as an extra $50 per year, according to McCullough’s study. The study concludes that the plant should be replaced with purchases of cheaper market alternatives, which McCullough estimates would save ratepayers $1.7 billion over the next 17 years. The facility is ‘significantly’ costlier than other nuclear plants, the study says, in part, because it’s an older, stand-alone plant.”

April 7, 2014 Energy consultancy identifies likely victims of Barclays’ alleged market manipulation Platts Inside FERC, Bobby McMahon

“Barclays Bank’s alleged market manipulation in the West from 2006 to 2008 likely injured a host of power entities in the region, according to an analysis by the energy consultancy McCullough Research. In an analysis released late last month, the firm reviewed data from the period in question along with FERC’s order finding that the bank and four of its former traders allegedly manipulated electricity prices in California.”

February 14, 2014 Why Not Do a Market Test of Columbia Generating Station? Clearing Up, Jude Noland

“‘One might argue the Kalama Energy Center numbers are too low, McCullough said; but even those costs were too high for that project to be viable, as the market was even lower. “It’s very hard to beat the current market, which is the issue that is really the central theme of the PSR report,” he said. “We’ve had five years of market prices lower than the price of power at CGS; let’s see if there’s a better deal out there than operating the plant.'”

February 13, 2014 Nuclear fuel deal has Northwest ratepayers speculating in a risky commodity The Oregonian, Ted Sickinger

“‘McCullough, for one, insists this is no deal at all for customers of the Bonneville Power Administration, who buy the plant’s output and financially backstopped the fuel purchase. He says it didn’t come through the normal channels, it doesn’t fit Energy Northwest’s typical fueling plans and it didn’t receive adequate vetting for a project of its size. At its most basic level, he says, its commodity speculation.'”

January 30, 2014 BPA: Elliot Mainzer officially named administrator; looks to firm up leadership team Oregonlive, Ted Sickinger

“‘On all the searches we did, he was not involved in the California trading activity or the Canadian activity,’ said Robert McCullough, managing partner of McCullough Research, which helped numerous public and private clients unwind Enron’s accounting, decipher tapes and document trading after Enron’s collapse. ‘He has a clean bill of health in terms of the 10 million Enron documents we have in our files.'”

January 27, 2014 Newsweek Says Washington Nuke Plant Overpaid for Fuel Willamette Week, Nigel Jaquiss

“The problem, according to the article’s author, Pulitzer-prize winner David Cay Johnston, is Energy Northwest didn’t need the fuel for its Richland, Wash. plant, and and paid at least a quarter of a billion too much.”

January 23, 2014 Kentucky-Fried Politics Newsweek, David Cay Johnston

“The true (and mostly hidden) costs of this deal – and how it deftly siphoned many millions from the Pacific Northwest to Kentucky – became known only after an independent economist in Portland, Ore., dug through the official files and contracts and wrote a 212-page report in December.”

January 15, 2014 Oregon Economist Challenges Analysis Keeping NW’s Only Nuclear Plant Alive Electricity Policy, Kennedy Maize

“The Energy Northwest comparison of the existing nuclear plant with new gas generation is also skewed by market purchase assumptions, says McCullough. The utility paper based its cost conclusions on closing the nuke ‘midway through a refueling cycle and then purchasing its full output at $32/MWh until the new power plant is ready, whether or not the energy was needed.’ McCullough comments, ‘Put colloquially, closing the plant earlier than the next fueling cycle is like throwing out the food already in your refrigerator because you don’t like the advertised prices at the grocery store.’”

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2013

December 27, 2013 New Energy Struggles on Its Way to Markets New York Times, Matthew L. Wald

“Output from the two has sometimes forced the Columbia Generating Station in Washington State, the region’s only surviving nuclear reactor, to cut back its production. One recent study found that shutting down the reactor would save consumers $1.7 billion, partly because it cannot run full time, and partly because its costs are higher than some other technologies.”

December 18, 2013 The Not-So-Green Machine Willamette Week, Nigel Jaquiss

“The report’s author, Robert McCullough, says mining and processing Energy Northwest’s uranium fuel produces enormous amounts of greenhouse gases. ‘Energy Northwest has frequently claimed the Columbia Generating Station is carbon-free,’ he says. ‘That’s not true.'”

December 11, 2013 Costly To The Core Willamette Week, Nigel Jaquiss

“McCullough says we could replace the plant with cheaper power and save ratepayers $1.7 billion over the next two decades. ‘The people who are paying for this plant,’ he says, ‘should want it closed.'”

December 10, 2013 Report calls Northwest’s lone nuclear plant a money drain Portland Tribune, Steve Law

“Closing the Northwest’s lone nuclear power plant could save taxpayers $1.7 billion over the next 17 years, according to a new report commissioned by the Oregon and Washington Physicians for Social Responsibility. “

July 23, 2013 Ban JPMorgan from California’s electricity trading business Los Angeles Times, Michael Hiltzik

“The biggest problem in California, McCullough says, is that power bidding in the state is done in secret — unlike other states where bids and offers are made in public. That allows for more manipulation and may help explain why wholesale power prices in California tend to be higher than in surrounding states.”

June 6, 2013 Feds back California on JPMorgan energy trades Sacramento Bee, Dale Kasler

“Robert McCullough, an energy consultant in Portland, Ore., said the firm was ‘manipulating the fine print to get the results they wanted.'”

May 19, 2013 Enron no lesson to traders as EU probes oil-price manipulation Bloomberg News, Ben Moshinsky, Lynn Doan and Jim Brunsden

“‘We’re making exactly the same mistakes we did with Enron, just with a different commodity,’ Robert McCullough, an energy consultant, said by telephone from Portland, Oregon. ‘The same manipulation we saw in electricity and gas pricing is what we’re seeing in oil.'”

May 16, 2013 Too nice for voter fraud? Some say OR election system vulnerable despite few cases Northwest Watchdog, Shelby Sebens

“‘This is a very Oregon moment,’ researcher Robert McCullough of the energy consulting firm McCullough Research said. ‘The Pacific Northwest is a very honest area, and so we have little in the way of checks and balances. But luckily, we also have very few villains.'”

April 24, 2013 Studies mull impact of closing nuclear power plant near Richland Tri-City Herald, Annette Cary

“McCullough, an economist who serves on the committee that oversees Reed College’s small nuclear research reactor in Portland, thought it seemed reasonable when approaced by environmentalists to see if shutting down the Energy Northwest reactor early could produce significant savings.”

April 24, 2013 Northwest physicians group hires economist to evaluate Hanford Nuclear Plant Wall Street Journal

“The Washington and Oregon chapters of Physicians for Social Responsibility have hired Robert McCullough of McCullough Research to examine the business case for an early retirement of the Columbia Generating Station nuclear power plant”

The market price of regional electricity in the Pacific Northwest has now fallen below the price of operating the plant. Additional article here.

A Northwest physicians group is paying for a full exam of the Columbia Generating Station nuclear power plant. Additional article here.

March 25, 2013 Oil and electricity: A compare-and-contrast tale of two regulators McClatchy Washington Bureau

“Last year’s West Coast price spikes amid ample supplies added to the urgency in determining whether excessive financial speculation is driving price volatility.”

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2012

December 10, 2012 State’s power-plant fight with JPMorgan Chase is a legacy of deregulation mess Sacramento Bee, Dale Kasler

“‘There’s still a bit of gaming the system,’ said Robert McCullough of McCullough Research in Portland, Oregon. ‘It is better, it’s not good enough.'”

December 6, 2012 Even U.S. senators complain about gas prices The Oregonian, David Sarasohn

“‘We could not find the outages,’ Robert McCullough said. ‘It doesn’t mean there weren’t any, but the reports weren’t accurate. At the moment, I think they’re pretty suspicious.'”

November 30, 2012 Rachel Maddow Interviews Senator Cantwell Rachel Maddow, MSNBC

“What we really need now is for the Department of Justice to use their full power and get to the bottom of this.”

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November 27, 2012 Senators seek U.S. probe of refineries’ actions in gasoline market Los Angeles Times, Ronald D. White

“‘Potentially market-making information, misleading reports of shutdowns could create or exacerbate a perceived supply shortage and artificially drive market prices to unjustifiably high levels,’ the letter to Holder says.”

November 27, 2012 Western lawmakers seek probe of refineries AP, Kevin Freking

“An analysis by McCullough Research indicates that gasoline inventories were either increasing or remaining at historic five-year averages during the highest price spikes.”

November 27, 2012 Senators Ask Justice to Probe California Gasoline Prices Reuters, Roberta Rampton

“The senators cited a report from independent energy consultant Robert McCullough that said two West Coast refineries continued to operate throughout May despite reports they were shut for maintenance.”

Letter to the Department of Justice here.

Also see the McCullough Research report here.

November 27, 2012 Gas price spikes disguise real problems with California market Los Angeles Times Times, Michael Hiltzik

“McCullough, whose contention inspired Tuesday’s call by the six senators for a federal investigation, says tighter regulatory oversight of the refinery industry is essential. ‘No specific agency has regulatory authority over oil and gasoline markets,’ he says. ‘No specific agency accumulates data on West Coast markets in sufficient detail to provide a check on the exercise of market power.'”

November 27, 2012 Western senators want refineries probed over high gasoline prices McClatchy Newspapers, Kevin G. Hall

“West Coast motorists were led to believe that the price spikes were tied to outages and production problems, but McCullough showed that inventories were building at a time when there were news reports, which refiners didn’t dispute at the time, of possible supply shortages. “

November 27, 2012 Gas Prices: Did oil firms manipulate market, senators ask Press Enterprise, Ben Goad

“The McCullough report found that such manipulation could be easy to coordinate between companies. ‘In highly concentrated industries, the exercise of market power through production reductions or cooperative pricing can require no more than an email or a phone call.'”

November 20, 2012 Fox Business Interview with Robert McCullough Fox Business

“There have been no holes poked in it yet. We have not had a single substantive response. There’s this question of ‘does a refinery have smoke even if its operating partially?’. We didn’t go on the total. We actually went through a device by device analysis. We identified the specific devices that were down and then compared these with the emissions from these devices. Three of the refineries showed a discrepancy in the Bay Area.”

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November 16, 2012 State seeks answers in gas price spikes San Francisco Chronicle, David R. Baker

“McCullough argued that the state needs refineries to report their planned and unplanned repairs, with that information made readily available to the public. ‘Markets work best in the light,’ McCullough said. ‘For our most critical commodity, we need to make this as open as possible.”

November 15, 2012 California lawmakers weigh moves to ensure gasoline supply Chicago Tribune, Rory Carroll

“‘This is a black hole in our energy picture,’ he said at a hearing of the state Senate Select Committee on Bay Area Transportation. ‘We know very little about what is happening in those markets.'”

November 14, 2012 Study: West Coast refineries operated during gas price spikes McClatchy Newspapers, Kevin G. Hall

“‘It certainly does not prove collusion among the principal suppliers, since specific data by refineries is difficult to procure,’ McCullough’s report said. ‘However, the data does suggest the need for an investigation on a refinery-by-refinery level.'”

California gas price spikes not tied to refinery outages. Additional article here.

New research shows that refiners continued to produce gasoline in periods when the public was told the contrary. Additional article here.

November 14, 2012 Study: West Coast refineries operated during gas price spikes USA Today, Michael Winter

“This means that in California, the nation’s most populous state, seven major players control most of the supply. They are vertically integrated, refining oil into gasoline and getting involved in the retailing of gasoline in the wholesale market. That system, McCullough said in an interview, lends itself to a market concentration that allows producers to subtly coordinate their prices.”

July 30, 2012 Electricity trading probed The Sacramento Bee, Dale Kasler

“‘These things are hidden eight levels down in the computer programming,’ said Robert McCullough of McCullough Research in Portland. ‘If a computer doesn’t catch you, you’re not caught.'”

July 28, 2012 Steffy: Worst of both worlds likely for Texas power consumers Houston Chronicle, Loren Steffy

“‘At every stage, they go further and further from competitive markets,’ Robert McCullough, a Portland, Oregon based energy analyst who follows deregulation issues, told me recently.”

July 23, 2012 Steffy: Utility commission forgets the public Houston Chronicle, Loren Steffy

“‘They’re basically a license to steal,’ said Robert McCullough, a Portland, Oregon based energy analyst who follows deregulation issues. ‘They essentially give advanced permission for market behavior that under any other conditions would be outrageous.'”

July 18, 2012 Manipulation of California energy market gives consumers a jolt Los Angeles Times, Michael Hiltzik

“‘There’s nothing really new under the sun,’ says Robert McCullough, a Portland, Ore., energy expert who reviewed the ISO complaint at my request. ‘But it’s a cost you’re paying in your monthly bill.'”

June 13, 2012 What’s really behind high gas prices? Oregon Business, Robin Doussard

“Consumers and businesses have all been severely impacted by the high gas prices. It might not be surprising that the reason could be pure greed, but it sure makes the blood boil. Oregon’s economic recovery is slow going and this adds insult to injury.”

June 13, 2012 Think the fix is in on gas prices? New report may back you up KATU News, Anita Kissée

“McCullough’s new report ‘Analysis of West Coast Gasoline Prices’ released June 5 says oil refineries may have intentionally created a supply shortage this spring just to charge Northwest drivers inflated prices, and they reportedly made almost $50 million a day because of it.”

June 12, 2012 Oregon, Washington gas prices continue to fall as report raises suspicions of market rigging The Oregonian, Joseph Rose

“Robert McCullough, the Portland analyst who helped topple Enron over predatory electricity trading a decade ago, has issued a report arguing that gasoline prices should have never reached this spring’s dizzying, budget-draining heights.”

June 11, 2012 Washington Senator Wants Answers On High Gas Prices Boise State Public Radio, Scott Graf and Kate Elston

“‘When that happens in the real world, we’d be pretty suspicious,’ McCullough says. ‘A local hardware store has a fire and the other hardware stores close and you have to pay $100 to buy a hammer, you’d be calling the local district attorney to look into it.'”

June 8, 2012 Investigation launched into high West Coast gas prices Dan Kerman, KRON4News

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“The key question is this: Did a handful of West Coast oil refineries work together to reduce production to cause a spike in gas prices on the West Coast?”

June 8, 2012 High gas prices in the Northwest Reggie Aqui, KGW News

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“We do not have the Federal Energy Regulatory Commission on the beat. There is no cop on this beat. We have to rely on our elected officials to ask the Federal Trade Commission to start requesting those materials”

June 7, 2012 High Gas Prices Bring Call for Investigation McClatchy Newspapers, Kevin G. Hall

“The McCullough Research report, published Tuesday, questioned whether the historically low gasoline inventories on the West Coast were really a result of a fire Feb. 17 that idled the BP plant for about three months.”

Senator questions why refineries cut production. Additional article here.

Senator seeks probe into high West Coast gas prices. Additional article here.

Also see the McCullough Research report here.

Also see US Senator Maria Cantwell’s letter to the FTC here.

Also see US Senator Maria Cantwell’s press release here.

May 21, 2012 Keeping the Lights on in Texas: Will big profits spur new power plants? State Impact, Dave Fehling

“‘Texas is the only state in the U.S. that has this curious system,’ said Robert McCullough, of McCullough Research in Portland, Oregon. ‘Not only are we creating an incentive not to build new plants, we’re creating an incentive that might lead some traders to create artificial shortages. Now, that sounds like a conspiracy theory and it is a bit, but it’s not as if it’s a conspiracy theory that we haven’t seen before.'”

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2011

May 20, 2011 In depth: Where next for Cape Wind as loan guarantee is frozen? Recharge, Richard A Kessler

“Analyst Robert McCulloch argues that the DOE decision is a serious setback for Cape Wind. ‘I’m glad I’m not on their side of the table with Wall Street. They still have to finance this and it is not what you would call an easy sell.'”

March 29, 2011 Expert: SNG plant raw deal for ratepayers The Bloomington Alternative

“Robert McCullough’s testimony revealed a complicated ‘derivative’ scheme based on the price of various commodities over time. Customers are not paying for service, or a natural gas substitute, but instead are paying for a financial hedge to cover the losses and share in the profits, if any, that the plant’s owners might make. McCullough’s testimony shows that if the contract were in place today, it could lead to a loss to ratepayers of as much as $500 million.”

February 15, 2011 Texas grid operator faces questions over blackouts The Texas Tribune, Kate Galbraith

“A report prepared for AARP in 2009 notes that the Australian market requires disclosure of power plant failures and other related information after two days. Robert McCullough, who heads an Oregon-based research firm that prepared the report, said that, in addition, ‘Texas does not make very detailed trading data available on the web as all other U.S. states do.'”

“Transparency in ERCOT: A No-cost Strategy to Reduce Electricity Prices in Texas,” the May 5, 2009 report by McCullough Research, can be found here.

January 27, 2011 President Obama sings Deval Patrick’s tune The Boston Herald, Jay Fitzgerald

“Robert McCullough, an Oregon energy analyst, expressed doubt whether the nation, or Massachusetts, can create many jobs by investing public money in clean-energy companies. ‘It’s not a question of vision, but it’s a question of implementation,’ said McCullough, saying government has a bad track record of ‘backing failures.'”

January 17, 2011 The messed-up wholesale electricity market The Baltimore Sun, Jay Hancock

“I guess it’s hard to blame the generation companies. Why should they build new capacity when it would mess up the present system in which they get paid for merely existing? But it demonstrates a highly flawed wholesale system — I won’t call it a wholesale market because, as Robert McCullough keeps pointing out to me, real markets don’t require 400 PJM bureaucrats to set the rules.”

January 2, 2011 Feds wind plan may zap Massachusetts The Boston Herald, Jay Fitzgerald

“‘It’s very expensive news for New Englanders,’ Robert McCullough, an energy analyst in Oregon, said of the announcement last week that the federal government is looking to lease deep-ocean waters for up to 4,000 megawatts of additional offshore wind development.”

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2010

November 23, 2010 Last big hurdle passed for Cape Wind The Boston Globe, Beth Daley

“The state Department of Public Utilities gave permission yesterday for National Grid to purchase half of Cape Wind’s power, removing the last significant hurdle for construction to begin on the controversial wind farm in Nantucket Sound next year. The agency, however, refused to approve a second agreement for the sale of the project’s remaining power. …’Every time they get one of these halfway results, it reduces their ability to finance,’ said Robert McCullough, an Oregon-based energy consultant who is not involved in the Cape Wind project but worked for opponents of a proposed wind farm off Block Island.”

Also see Boston.com’s The Green Blog post here.

October 24, 2010 Obscure electricity charge enriches power sellers The Baltimore Sun, Jay Hancock

“A few years ago, grid administrators outside Philadelphia changed the rules for selling wholesale electricity in such a way that Maryland consumers will end up paying an extra $5 billion or so for their kilowatts from 2007 to 2014. …The money was supposed to lure those companies and others to build generation plants, thus easing electricity shortages. But the generators haven’t been built. …’It is a joke,’ says Robert McCullough, an economist and energy consultant hired by the Illinois attorney general to analyze similar electricity charges in that state. ‘We can say without any question that it is completely outlandish.'”

October 4, 2010 Cape Wind rates will whack businesses, hospitals, schools The Boston Herald, Jay Fitzgerald

“[A] review of National Grid’s own estimates of the above-market prices it would pay for Cape Wind power shows that local businesses, nonprofits and other large energy users will be paying far more [than the estimated $1.25 a month increase for residential customers] – in some cases as much tens of thousands of dollars per year. And experts say most of those costs will be passed on to the same consumers who, as rate- and taxpayers, will be paying for the cost of planting the turbines off Nantucket Sound – and footing higher energy bills once the project is running. ‘As they say, there are lies, damned lies and statistics,’ said energy analyst Robert McCullough. ‘This is a very expensive project.'”

August 5, 2010 PUC UPDATE: ‘I don’t know what we’ll decide’ The Block Island Times, by Jane Vercelli and Steve Stycos

“Tuesday’s final witness [at the Rhode Island Public Utilities Commission hearing], energy expert Robert McCullough, testified on behalf of seven citizens of Block Island and North Kingstown, including Republican state Rep. Lawrence Ehrhardt, who oppose the project. McCullough said the power purchase agreement was not commercially reasonable because it estimates costs without stating what equipment would be used on the project. ‘We don’t know where the prices are coming from,’ he stated, ‘We don’t even know what the equipment is.'”

August 4, 2010 Deepwater Contract Criticized The Providence Journal, by Peter B. Lord

“[In written testimony, Robert] McCullough said he found the prices in the [proposed contract governing how National Grid would buy electricity from a wind farm developed by Deepwater Wind off Block Island] are significantly higher than prices for similar projects either under way or recently completed in Europe. ‘The cost figures give the appearance of being reverse-engineered from a required rate of return rather than derived from basic engineering estimates. The rate of return seems high with any reasonable level of leverage, and due diligence by the purchaser was lacking. Finally, the proposed contract’s pricing sections are poorly written and several other sections may contain drafting errors.'”

August 4, 2010 PUC Holds hearing on Deepwater Contract The Providence Statehouse Exhaminer, by Ryan Drugan

“As state leaders give their support for the Deepwater contract agreement with National Grid, small business and concerned citizens voice their opposition. ‘The cost figure give the appearance of being reverse-engineered from a required rate of return rather than derived from basic engineering estimates,’ stated Robert McCullough an energy consultant from Oregon working on the Block Island wind farm project. McCullough commented that the agreement between Deepwater and National Grid is written poorly, contains numerous errors, and lacks key information regarding maintenance costs and the type of turbines that will be constructed.”

August 2, 2010 New York Attorney General Urges Probe of Electric Costs Bloomberg BusinessWeek, by Michael Virtanen

Richard Brodsky, candidate for Attorney General for the state of New York, cited a McCullough Research report that analyzed the bidding at the New York Independent System Operator and found that “every day at least one producer submits maximum $1,000 bids, while production costs even with expensive fuels like natural gas are significantly less than $100 an hour.”

“The New York Independent System Operator’s Market-Clearing Price Auction is Too Expensive for New York,” the March 3, 2009 report by McCullough Research, can be found here.

July 13, 2010 Keep Energy In Line The Hartford Advocate, Robert McCullough’s Letter to the Editor

“Connecticut suffers and Dominion profits from the distorted prices set by the bureaucrats who run the New England Independent System Operator’s wholesale electricity markets. These markets need a thorough [overhaul] – starting with making the bids, bidders, and calculations public – so that effective competition can bring Connecticut’s wholesale power costs in line with those elsewhere in the United States.”

June 22, 2010 The Pros and Cons of Nuclear Power: America is entering a nuclear “renaissance,” but can we afford it? The Hartford Advocate, by Daniel D’Ambrosio

Although the Millstone nuclear power plant in Waterford near New London produces about 55 percent of the electrical power generated in the state, there is little incentive for Connecticut legislators to encourage new nuclear plants. According to Rep. Vicki Nardello, (D-Prospect), “under the rules of the state’s deregulated market Millstone can charge the same for its power as a power plant fueled by natural gas, the most expensive source of power.” An analysis by McCullough Research has shown that Dominion Resources, the Virginia-based company that owns Millstone, “made $440 million in 2009 before taxes, yielding a 57-percent rate of return on investment and a return on equity of 115 percent.”

June 14, 2010 Cape Wind-fall Up on Cards Stock Watch, by Narendra Jakhad

“Developers in Cape Wind could make massive gains by selling off their rights to the wind farm proposed. …It is said to be a common practice amongst energy companies to arrange for all necessary permits and new power plant financing before turning it over to other investors even as the projects are ready to go. Robert McCullough who is an energy expert at the McCullough Research center in Oregon, feels this is how entrepreneurs work and there is nothing unethical about a rapid turnover in the energy business.”

June 13, 2010 Could be a Cape Wind-fall: Turbine developers sell Texas project after gettin OKs The Boston Herald, by Jay Fitzgerald

“Cape Wind developers could make big bucks if they sold off the rights to the proposed offshore wind farm, as they did last year when they unloaded a new wood-burning power plant in Texas before construction even began. …A spokesman for the controversial Cape Wind project off the coast of Cape Cod says the developers have every intention of seeing the project through to the end …[b]ut experts say its common practice for energy companies to line up the necessary permits and financing for new power plants and then turn around and sell ready-to-go projects to other investors. “Rapid turnover is the name of the game in the energy business,” said Robert McCullough, an energy expert at McCullough Research in Oregon. “It’s often the smart play. There’s nothing unethical about it. It’s how entrepreneurs work.”

May 18, 2010 Cape Wind’s Plan B? You pay if federal tax credit falls through, electric rates will rise The Boston Herald, by Jay Fitzgerald

“Tucked in National Grid’s 159-page rate filing is an appendix calling for Cape Wind’s proposed first-year rate to rise from 20.7 cents per kilowatt hour to 22.8 cents – or by 10 percent – if the developer can’t secure a lucrative, investment tax credit. Robert McCullough, an Oregon energy consultant, said the back-up rate hikes are ‘not outlandish’ – and they’re perhaps necessary if Cape Wind is ever to get built.”

May 11, 2010 Higher rates blowing in: Cape Wind contracts could generate $6B tab over 15 years The Boston Herald, by Jay Fitzgerald

“The controversial Cape Wind project could end up costing ratepayers as much as $6 billion over 15 year – and provide utilities with multimillion-dollar bonus incentives if they buy electricity from the planned off-shore wind farm…’By any standard, this is a very high price for energy,’ said Robert McCullough, president of McCullough Research, an Oregon energy consulting firm.”

May 8, 2010 Cape Wind rate shock: Electricity will cost twice as much as power plants The Boston Herald, by Jay Fitzgerald

“Cape Wind, which wants to build 130 wind turbines off the coast of Cape Cod, and National Grid announced yesterday that they’ve reached an agreement to start charging customers 20.7 cents per kilowatt hour in 2013 – more than double the current rate of electricity from conventional power plants and land-based wind farms…..’I’m glad it’s your electric bills and not mine,’ said Robert McCullough, president of McCullough Research, an Oregon energy consulting firm, referring to Cape Wind’s prices.”

April 13, 2010 Alliance touts power of few rules The New Haven Register

“A study…contends that Connecticut has received substantial benefits from the deregulation of its electrical industry in 2000…But according to Robert McCullough, managing partner of McCullough Research of Oregon, “month after month, electric rates continue to increase in Connecticut.”

April 8, 2010 Indian Point is a Cash Cow Jonathan Fahey, forbes.com

“It may cost $1 billion to change the way the two nuclear reactors at Indian Point on New York’s Hudson River keep themselves cool in order to satisfy environmental protection regulators. Sounds like a bundle of money, and it is…But don’t shed too many tears for the plants’ owner, Entergy. The plants are cash cows. According to an analysis done by longtime utility consultant and analyst Robert McCullough, in 2009 the two reactors brought in $982 million in sales and $436 million in profit before income taxes.”

April 3, 2010 Power outage questions probed SignOnSanDiego.com, Onell R. Soto, Union-Tribune Staff Writer

The reasons behind the shut-off of the Otay Mesa plant on April 1st remain unclear. SDG&E and state grid operators are still investigating what happened. “Rules for running an electricity grid call for redundancies — generally the system has to have enough backuppower to be able to take the loss of its biggest power plant or transmission line plus 5 percent, said Robert McCullough, a utility consultant in Portland, Ore. San Diego has just two connections to the rest of the grid, so managing supply and demand here is easier than elsewhere…’The hypothesis that comes up … is somebody entered the wrong number into the computer,’ he said.”

March 17, 2010 Lawmakers look at energy cost The New Haven Register, by Luther Turmelle

[T]he operator of the Millstone Nuclear Power Plant in Waterford–Dominion Energy of Virginia–would be subject to the [windfall profits tax proposed by Connecticut bill HB 5505], according to a report prepared for the Energy and Technology Committee by McCullough Research, a Portland, Ore., consulting firm.

“Dominion’s net pre-tax profit from the Millstone 3 generating unit was $440 million in 2009, which translates into a 57 percent rate of return on the company’s investment and a return on equity of 115 percent, according to the report.”

March 14, 2010 Smart power meters? Well, sure. Someday. Baltimoreson.com, by Jay Hancock

‘There are a lot of simple things you can do, and most of them don’t require the installation of a handy-dandy meter,’ says Robert McCullough, a respected energy consultant and gadget geek. He bought and installed a smart meter on his Portland, Ore., office, but for most people, he thinks smart meters are of questionable value.”

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2009

December 2, 2009 U.S. consultant backs whistleblower in Hydro audit CBC News

Hydro CEO Bob Brennan appeared before a provincial government sub-committee on Nov. 17 and defended the utility against the whistleblower’s claims. He said a report from research consultants ICF International shows her allegations are incorrect…But on Wednesday, CBC News obtained a consultant’s document from Portland, Ore.- based McCullough Research that said the ICF report contains outdated data and was ‘hastily prepared.'”

See also US energy Consultant comes forward to back up Whistleblower, from the Manitoba Post, Wednesday, December 02, 2009

November 8, 2009 The Shocking Truth: One politician stopped electric rate reform By Paula Panzarella, The New Haven Register

“There were extensive discussions and presentations in the Energy and Technology Committee as to how renewable energy could be developed and encouraged by the state. Many Connecticut municipalities, environmental groups and businesses took part in the hearings, including AARP, which sponsored Robert McCullough, an energy expert from Portland, Ore., to give a presentation to the Energy and Technology Committee about the concrete way a state energy authority could be developed, and how it would lower electric rates.

October 19, 2009 Electricity ‘Rip-Off’ is $hocking “Without even selling one watt of power, three electricity-generating companies managed to rip off New Yorkers for an untold amount of money, the state’s powergrid operator says in a shocking admission to federal regulators. It’s the latest bigbucks cash grab alleged to have happened right under the nose of the New York Independent System Operator, whose bungles are estimated to have cost consumers hundreds of millions of dollars… The ISO won’t disclose how much money is involved, when the overcharges happened, or the names of the three companies.

September 14, 2009 NYISO seeks changes to energy bidding “Three upstate power providers may have cost consumers money by artificially inflating auction bids, the nonprofit that operates the state’s power grid has told federal regulators. An independent study released earlier this year alleges that New York’s consumers pay $2 billion a year more than they should for electricity because the state’s auction system is flawed. The study by Robert McCullough of McCullough Research in Oregon was made public in March by Assemblyman Richard Brodsky, D-Westchester. McCullough is the energy expert who helped uncover Enron Corp.’s energy market manipulation.”

September 11, 2009 3 Generators may have cost consumers “It turns out that you may have been paying too much for your electricity bill after all. The New York Independent System Operator, the North Greenbush nonprofit that operates the state’s wholesale electricity market, has told federal regulators that three power plants in upstate New York may have been trying to inflate profits by making artificially high bids. The NYISO won’t publicly reveal the names of the generators — or just how much they might have cost consumers.”

June 5, 2009 Report: Deregulation of electricity yields big profits for companies, costs NY ratepayers “New York’s deregulated electric market allows generation plants to reap massive profits at the expense of taxpayers, according to a report released Friday. Industry representatives rejected the findings that the state’s top 15 generators received inflated profits. Assembly corporations committee Chairman Richard Brodsky, a Westchester County Democrat, said the generators have an annual rate of return between 31 and 186 percent. Brodsky released the report with Robert McCullough, whose firm McCullough Research conducted the study. “These are unconscionable numbers. No other industry has a profit margin averaging anything near these numbers annually,” Brodsky said.

May 5, 2009 Report Calls for More Transparent Texas Wholesale Market “The deregulated electricity market in Texas has been a bust for consumers due to a poorly structured wholesale market and a lack of transparency, according to a McCullough Research report prepared for the American Association of Retired Persons (AARP). While deregulated market defenders have said high prices in Texas last year were the result of high natural gas prices, the McCullough report said that’s not the case.”

April 22, 2009 McCullough finds bids in RTO markets are often ‘100 times higher than common sense would expect’ “The balancing energy markets run by regional transmission organizations often are plagued by hockey stick bids that can be “a hundred times higher than common sense would expect,” energy consultant Robert McCullough said in a report, Analysis of the Balancing Energy Market. The balancing energy markets frequently set prices in the larger markets at very high levels, he said. At least some non-economic bidding occurs every day in every RTO, he said.”

April 9, 2009 Oil: Just What Happened In 2008? “While oil is arguably the U.S. economy’s most important commodity, it is ironic that no agency of the U.S. government has been assigned the task of investigating and explaining the extraordinary price changes of last year.”

March 27, 2009 Senate Ponders Legislative Options; FERC Backs Preemptive “Cease and Desist” Authority “Although we fear that the oil market may have become dominated by speculators, we do not know who they are, or their possible impacts,” explained Robert McCullough. Oil, natural gas and the electricity industry are interconnected with commensurate effects on the entire economy. According to McCullough, the inability of the federal government to fully investigate oil price behavior in 2008 is fundamentally a data problem, and the legislation that Congress is considering “is a step in the right direction,” as it will expand the EIA’s ability to track oil inventories within the U.S. by owner.

March 22, 2009 The Case Against Fowler’s Bonanza “Besides, McCullough notes, “The outrage you’re seeing, unfortunately, is occurring after the storm is over.” With board and shareholder approval, Fowler has already sailed off with the $4.5 million.”

March 19, 2009 Assemblyman Blasts NYISO Over Rates “New Yorkers pay some of the highest electric rates in the nation – 45 percent higher than the national average. Critics say there’s something funny with the way electricity is bought and sold. MCCULLOUGH: If you walked into the local grocery store and you found that a loaf of bread was $1000, you’d have a pretty good sense that something was wrong with that grocery store.”

March 12, 2009 You Are Too Stupid To Understand Electricity Prices Say Utilities CEOs “The story quotes multiple executives saying electricity pricing is “complicated.” Darn right it is. But because utilities won’t clearly explain what’s happening, perhaps for fear of being exposed, consumers are expected to just accept on face value what’s happening to them. With the coming changes in energy, consumers might not accept higher prices for much longer.

March 10, 2009 Investigate this shocking charge: Is there Enron-style manipulation of N.Y. electric bills? “Are New Yorkers really being ripped off to the tune of more than $2 billion a year on their electric bills? Energy expert Robert McCullough thinks so. And he has a track record of sniffing out hanky-panky in the power grid. McCullough, a consultant based in Portland, Ore., was among the first to blow the whistle on the Enron scandal – correctly diagnosing the brazen market manipulation that triggered spikes and brownouts across California in the late 1990s.

March 6, 2009 Assembly Committees Hold Hearing to Discuss NYISO Practices and High Electric Prices “A joint hearing by the Assembly Committee on Energy and the Committee on Corporations, Authorities, and Commissions was held on March 5th to discuss the practices of the New York Independent System Operator (“NYISO”). The NYISO is a not-for-profit corporation that began operations in 1999, operating New York’s bulk electricity system and administering the wholesale electricity markets. The Assembly Corporations Committee, chaired by Richard Brodsky, held a press conference earlier in the week to release a study conducted by McCullough Research showing that due to the NYISO’s spot market rules and practices, New Yorkers paid $2.2 billion a year in artificial and unnecessary electricity rates on their electric bills.

March 4, 2009 Assemblyman Blasts NYISO Over Rates “The 11-page study Brodsky touted was done by McCullough Research, an Oregon energy-consulting firm run by Robert McCullough.”

“…’What you have here is price fixing,’ Brodsky said. ‘Elegant price fixing. Even if there is not collusion, the system is nutty.'”

February 26, 2009 Washington Wind Power Headed to California “People who believe you can follow the green electron down the line” may bristle at the thought of selling that power out of state, says Robert McCullough, a Portland energy consultant. But in fact, “once you put them on the grid, you can’t tell them apart — a green electron and a brown electron are just figments of our imagination.”

February 25, 2009 Blumenthal Presses for State-Run Power Authority “The report, prepared for AARP by McCullough Research of Portland, Ore., recommends creating a state power authority modeled after the new Illinois Power Agency.” “AARP’s report outlines how a Connecticut Power Authority could bring competition and better serve the interests of the state in lowering energy rates for consumers and businesses.”

January 14, 2009 Expert Finds Flaws in Cost-benefit Analysis of ERCOT Market Overhaul “A key cost-benefit analysis examining the pending overhaul of the Texas wholesale power market in ERCOT is of questionable accuracy, with a national expert finding errors, unreasonable assumptions, discrepancies and a shortage of economic logic.

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2008

December 15, 2008 Rell Can Put Her Own Stamp on DPUC “With two vacancies on the state Department of Public Utility Control, and the likelihood of a third by the middle of next year, Gov. M. Jodi Rell has an opportunity to remake the regulatory agency in a way that she might find more to her liking.” “Look for someone with real business experience, someone who is a real-life problem-solver,” said Robert McCullough, managing partner of Portland, Ore.-based McCullough Research, an energy consulting firm. “The best state regulator is someone with a healthy dose of common sense, someone who is straight forward. That common sense is something you need; what you do not need is a career bureaucrat.”

September, 2008 CFTC Staff Report on Commodity Swap Dealers & Index Traders Page 62: “Robert F. McCullough, Jr., McCullough Research, August 2008 There is a strong possibility that the high level of concentration in the spot and future oil markets have made the market strategies of the principal market participants more significant than fundamentals – at least in the short term.”

September 15, 2008 Cantwell Says She’s Working to ‘Shed Light’ on ‘Dark’ Oil Markets “‘This is exactly the same pattern Enron’s manipulations showed in 2000 to 2001,’ McCullough said in a statement. ‘The CFTC’s report misses the fundamental issue by restricting their analysis to periods before the July 2008 price spike. When the bandit leaves the bank, the money leaves with him.’ Masters and McCullough are among six witnesses scheduled to testify Tuesday before the Senate Energy and Natural Resources Committee, of which Cantwell is a member.” — Christopher Dunagan, Kitsap Sun

September 11, 2008 Are We Screwing in the Wrong Bulbs? “Unfortunately, the argument is bogus, says Robert McCullough, a former Portland General Electric executive. That’s because using less electricity does not mean less coal is burned. Since coal is cheap, power companies tend to keep their coal-fired plants running day and night; when demand for electricity ebbs, they cut back on more expensive natural gas, not coal.

August 26, 2008 PSC to rule on Iberdrola request — Democrat and Chronicle “Once you have the energy and transmission, there are any number of clever things you can do,” said Robert McCullough, managing partner of McCullough Research of Portland, Ore. “The (PSC) staff is entirely correct.”

July 12 , 2008 Top wholesale power rates leads to jolts “Robert McCullough… says the energy-only market could tempt manipulation efforts, such as generators withholding power from the grid to narrow the gap between supply and demand and make it more likely a high bid will be accepted.” — Tom Fowler, Houston Chronicle

April 28, 2008 FOX 5 Investigates Power Prices FOX 5, Washington, DC interviews Robert McCullough about the failures of Maryland’s electricity procurement auction.

April 7, 2008 Connecticut Lawmakers Warned of Power Missteps “As they grapple with consumer unrest over high electricity rates, Connecticut lawmakers were urged by a consultant to create a state power authority to bring down costs and stabilize the energy sector….. Robert McCullough warned against repeating mistakes made in California as well as in the Northeast.” — Rich Nemec, Power Market Today

March 28, 2008 BGE Settlement Settles Little “As the governor who promised to stop the BGE rate increase and got hammered for failing, Martin O’Malley surely must be happy to get something back for customers. But he might have gotten more….‘The price is surprisingly high,’ McCullough Research wrote. — Baltimore Sun, Jay Hancock

March 16, 2008 The Power Drain: The Pinch at Home – Many Residents Stung by High Cost of Utilities “According to a national analysis by McCullough Research for municipally owned utilities, electricity rates in deregulated states rose almost 40 percent, compared with 19 percent in states that remain regulated.”— Washington Post, Kirstin Downey

February 21, 2008 Societe Generale Trader posts record loss on trading scandal, subprime exposure “Societe Generale’s report detailed how the trader Jerome Kerviel offset his real positions in the market by creating fictitious hedged positions that eventually were discovered.”— International Herald Tribune, Nicola Clark

January 10, 2008 New Study on Missing Benchmark “The gap between electricity rates in regional transmission states and non-RTO states is widening and the Federal Energy Regulatory Commission needs to reinstate a missing benchmark to analyze the problem, says a new study… by Robert McCullough and Ann Stewart of McCullough Research. “— APPA Public Power Daily

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2007

October 14, 2007 Is energy fox minding the henhouse? “This month, after revealing that electricity rates could surge 35 percent for residents and up to 43 percent for businesses in 2010, PPL Corp. shrugged off responsibility for the looming hike, saying it does not set prices — the marketplace does. But the energy industry plays a critical role in policing the power market, which means the fairness of prices depends on the industry’s integrity and good faith….At the same time, the Federal Energy Regulatory Commission examines some, but no longer all, wholesale electricity rates to ensure they are ‘just and reasonable.’… Experts, however, have put forth a number of reasons why the power market might result in inflated prices…. ‘The secrecy in itself is a big part of the problem,’ said Robert McCullough, an electricity consultant who advised the Illinois attorney general. ‘Anytime you do things in a back room, you have created incredible potential for abuse.'”— Morning Call, Sam Kennedy

August 8, 2007 Let’s see why grid watchdog barked Here in Central Maryland we just got a 72 percent electric-price pop. We want as clear a view of our deregulated electricity market as Californians got of theirs after the Enron debacle, and this case looks like it’ll help. PJM is the nonprofit Pennsylvania company that supervises the grid and runs the wholesale electricity market from New Jersey to North Carolina. Maryland and other states have sought redress with the Federal Energy Regulatory Commission over claims by PJM market monitor Joseph Bowring that his bosses silenced him when he wanted to report price irregularities and outsized profits at generation companies. They want Bowring’s operation made independent. PJM’s apparently panicked offer to settle, disclosed Thursday, suggests that some very interesting evidence will surface if the case is pursued …. A lot of people would actually like to see the full set of information” at PJM, says Robert McCullough, an energy consultant who was deeply involved in the Enron case out West. “If we’re going to live with this institution the rest of our lives, it’s pretty important that we understand what’s going on with it.” — Baltimore Sun, Jay Hancock

June 26, 2007 Ex-Enron Customers Win One in Court “Snohomish County Public Utility District prevailed against Enron — again — last week when an administrative law judge ordered the bankrupt energy giant to disgorge $1.6 billion in illegal profits made from customers of West Coast utilities.Judge Carmen Cintron also ruled that $157 million in contract termination payments Enron was seeking from Snohomish were ‘unjust profits ‘…. Robert McCullough, a Portland energy consultant who has spent much of the past four years working on Enron-related cases, provided one of two accounting estimates of Enron’s energy trading profits used by the judge to reach her $1.6 billion decision. McCullough said that most of that money came from Northwest consumers and that PGE’s customers could be due a sizable refund. PGE was wholly owned by Enron until April 2006. It has never filed a claim on behalf of its ratepayers.” — Oregonian, Ted Slicking

April 17, 2007 Rebuilt PSC begins hearings to probe electricity-rate rise “A reconstituted state utility commission launches today its first investigation of the electric rate increase that stunned utility customers last year and led to the appointment of several new panel members. . . The initiative lumps Maryland with a handful of states stretching from Delaware to Montana that are scrutinizing deregulated energy markets amid a consumer backlash against rising energy costs. . . .The state of Illinois blamed flaws in a similar energy auction for soaring energy process among that state’s utilities. The Illinois attorney general filed a complaint last month with federal regulators, asking them to investigate allegations of price gouging among wholesale supplies. The complaint contains testimony from Robert McCullough, an energy consultant who said winning bids were 40 percent higher than prices available in the broader market at the time the Illinois auction was conducted.” — Baltimore Sun, Paul Adams

March 16, 2007 Madigan Blows Whistle Illinois Attorney General Lisa Madigan on Thursday alleged there is evidence of bid-fixing and collusion behind the state’s skyrocketing electric rates, and she formally asked a federal regulatory agency to reverse those rates and investigate the power suppliers of two major utilities. In a 31-page complaint filed with the Federal Energy Regulatory Commission, Madigan lays out what she says is evidence that last year’s power auction involving Ameren and ComEd might have been fixed to ensure that specific wholesale suppliers – including the parent companies of both utilities – got the most lucrative parts of that business. . . . Madigan’s office said it worked with a team of experts in compiling the complaint, including Robert McCullough, an expert on electricity trading practices who was involved in the federal investigation into Enron’s activities in Western electric markets.” — St. Louis Post-Dispatch, Kevin McDermott

March 15, 2007 Press Release: Illinois Attorney General Lisa Madigan Alleges Price Manipulation in 2006 Electricity Auction “‘Five million Illinois residents are unnecessarily paying electricity prices that are double the actual cost of generating electricity and 40 percent higher than electricity prices in the wholesale electricity markets,’ said Madigan. ‘We undertook an extensive investigation to find out why the prices produced by the auction were so high. This complaint follows that lengthy investigation of bidding patterns in the auction.’ . . . The analysis prepared by Robert McCullough concludes that the high prices produced by the auction are largely due to a lack of competition in Illinois electricity markets — which U.S. Department of Justice guidelines classify as ‘highly concentrated.’ He also uncovered evidence that electricity suppliers engaged in market manipulation – driving prices even higher.” — Office of Lisa Madigan, Robyn Ziegler

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2006

September 27, 2006 Report Says Amaranth Trader May Have Attempted to Corner Market The article quotes Robert McCullough saying he believes Amaranth attempted to corner the natural gas market and that the “lack of federal oversight” of energy markets and hedge funds by FERC, the CFTC and the SEC, and the CFTC is partially responsible. — NGI’s Daily Gas Price Index

July 11, 2006 Consultant Challenges Economists Over State of Competition Robert McCullough challenges several economists whose open letter urges policy makers to ‘stay the course’ on the electric competition. — NGI’s Power Market Today

June 30, 2006 Economists Express ‘Deep Concern’ over Wholesale Electricity Prices Economists Urge Policymakers to “Stay the Course” on Electricity Competition COMPLETE Letter to Secretary Salas which includes Open Letter toPolicymakers McCullough Research Responds to June 26, 2006 Open Letter to Policymakers

May 25, 2006 FERC Lawyer Denies Part in Enron Trades; She says she did not advise on questionable strategies while working for the energy firm “A former Enron Corp. lawyer who last month went to work for the Federal Energy Regulatory Commission on Wednesday vigorously denied involvement with the company’s questionable trading tactics, after two senators raised questions about her hiring. . . More broadly, however, [Robert McCullough States] ‘the question is not whether Mary Hain should be indicted,’ he said Wednesday. ‘The question is whether it’s appropriate for a federal regulatory agency to hire a lawyer who had such an intimate role with all these people who we know were committing these frauds.’ ” — Los Angeles Times, Jonathan Peterson

May 22, 2006 Gas Price Gouging evidence discovered; Sen. Cantwell Says FTC Report Leaves Many Questions Unanswered “Following Monday morning’s release of a Federal Trade Commission (FTC) report on post-Katrina gasoline price manipulation, Sen. Maria Cantwell (D-WA) renewed calls for increased oil industry transparency and swift approval of her legislation to enact a tough federal ban on gas price gouging. . . In addition to evidence outlined in the FTC report, a recent report by Portland-based energy consultant Robert McCullough found oil and gas market anomalies consistent with a practice known as “wash trading,” where simultaneous transactions are executed in order to deliberately inflate volumes and revenues. This tactic was used by the unregulated Enron subsidiary, EnronOnline, to manipulate energy commodity markets.”– U.S. Federal News

May 9, 2006 Markets vulnerable to manipulation – Testimony Robert McCullough testifies at a Democratic Policy Committee hearing that “regulating only a few electronic trading platforms is similar to allowing some travelers to skip security checks. . . . Everyone becomes less secure if obvious shortcuts around regulation exist.'” –Megawatt Daily

May 8, 2006 U.S. Senate Dems Seek Greater Energy Trading Oversight “At a Democratic Policy Committee hearing on energy trading, lawmakers said skyrocketing energy prices are reminiscent of the soaring electricity prices consumers saw in the West during the 2000-01 energy crisis – a time of high power prices, rolling blackouts, and manipulation by Enron Corp.(ENE).” Robert McCullough suggests, “Congress give the CFTC authority to make sure that electronic trading platforms are registered and regulated.” — Dow Jones International News, Maya Jackson Randall

May 8, 2006 Senator Cantwell Hearing on Energy Market Transparency Exposes Anomalies in Oil and Gas Prices A press release from the office of Senator Maria Cantwell (D-WA) says, “A new report from McCullough released at the hearing announced that oil and gas market anomalies exist that are consistent with a practice known as ‘wash trading’ where simultaneous transactions are executed in order to deliberately inflate volumes and revenues. This tactic was used by the unregulated Enron subsidiary, EnronOnline, to manipulate energy commodity markets.” — United States Federal News

May 8, 2006 Congress Learns That Enron-Like Market Fraud Still Exists; McCullough Research Uncovers More Enron Trading Schemes “McCullough Research will tell a Democratic Policy Committee oversight hearing today that U.S. gas and electricity trading is still vulnerable to the market schemes employed by Enron Corporation during California’s 2000-2001 energy crisis. ‘Widespread opportunities for fraud and manipulation exist today, even though most experts claim California’s crisis ended years ago,’ says Robert McCullough, manager of McCullough Research.” — Business Wire

May 1, 2006 Energy Crisis Case may set New Rules: Defining Criminal Conduct is at Stake The article quotes Robert McCullough saying, “‘I am not sure it is even possible to identify [trading] loopholes beforehand, let alone plug them,’ he said. “Simply put, would you shop at a supermarket where only insiders can check the receipts?'” — The National Law Journal, Pamela MacLean

April 19, 2006 Kelliher Questioned About FERC’s Rehiring of Ex-Enron Attorney and the Agency’s Recusal and Internal Communication Policies “The Los Angeles Times reported on Hain’s hiring in its April 8 edition. ‘Hain’s ‘apparent indifference to corruption seems like a very poor qualification as a regulator,’ Robert McCullough, a former Portland General Electric executive and energy consultant told the Times.'” — Foster Electric Report

April 17, 2006 FERC staff defends Enron settlement offer against criticism from Snohomish and others “Federal Energy Regulatory Commission trial staff defended itself last week against harsh criticism leveled at the proposed settlement it reached with Enron on compensation Enron should offer to two utilities for market manipulation. FERC trial staff and Enron on March 10 filed offers of settlement to be made by Enron to the Public Utility District No. 1 of Snohomish County, Washington, and the Metropolitan Water District of Southern California. . . . The proposed settlement from Enron and FERC trial staff would allocate up to $10 million in Class 6 unsecured claims to ‘non-settling participants,’ as FERC put it. But that probably would amount to no more than $2.29 million, said Snohomish and Met Water. They reinforced the point with an affidavit from consultant Robert McCullough. ‘According to Enron’s current bankruptcy plan, the Class 6 unsecured claims will be paid out at the rate of 22.9 cents per dollar. This means the $10 million in unsecured claims obtained by trial staff … is worth $2,290,000,’ said McCullough, who has worked for several years with Northwest utility clients.” — Platts Power Markets Week

April 16, 2006 Ex-Enron lawyer lands in federal energy post; Hiring draws fire; scope of her role at failed firm debated “At the peak of the California energy crisis, Mary C. Hain was a lawyer at Enron Corp.’s Portland, Ore., trading hub where she had a front-row view of practices that injected chaos into electricity markets and sent rates soaring. She once scribbled: ‘Answer questions, say nothing. Answer questions, finger others.’ Those notes from October 2000 were reviewed later by investigators looking into market-gaming among the energy traders whom she advised on legal matters. . . . ‘As a lawyer, her knowledge of the schemes and apparent indifference to corruption seems like a very poor qualification as a regulator,’ said Robert McCullough, an Oregon energy consultant who has scrutinized the actions of Enron employees during the troubling chapter of 2000-01.” — Chicago Tribune, Johnathan Peterson

April 11, 2006 FERC Spokesman: ‘Look at the Facts’ in Hiring of Ex-Enron Attorney “As news broke over the weekend that a former Enron lawyer has been hired at FERC as a trial attorney specializing in technical rate matters, a Commission spokesperson on Monday urged skeptics to ‘look at the facts,’ and not to attach a ‘stigma affecting someone’s career just because of the simple fact they worked at Enron.” — Power Market Today

April 10, 2006 PGE Shares Decline on NYSE Trading Debut “Despite Portland General Electric’s recent stock fall of 5% Robert McCullough states, ‘PGE is a peach of a utility’ and ‘the utility itself is in good shape.’ This article is not for distribution, please contact the publication directly.” — Seattle Post-Intelligencer, Tim Fought

April 8, 2006 U.S. Energy Commission Hires Ex-Enron Lawyer Robert McCullough questions the hiring of former Enron Lawyer Mary Hain by the Federal Energy Regulatory Commission (FERC). — Los Angeles Times, Jonathan Peterson

March 23, 2006 McCullough Skeptical of Texas Market’s Validity Robert McCullough comments on the Texas Market’s lack of transparency, and reminds the readers of past and current market manipulations. — Restructuring Today

February 15, 2006 City Continues to Dig into PGE’s Finances Robert McCullough was interviewed by Ley Garnett as part of an article about Portland General Electric and the City of Portland. Robert McCullough was hired by the City of Portland as a consultant in this matter. This article is not available for distribution, please contact the publication for a copy. — Oregon Public Radio (OPB), Ley Garnett

January 31, 2006 Hunch Becomes a Hunt PGE’s involvement with Enron and its tax payments “. The goal: to see if the company’s involvement with improper Enron Corp. energy shenanigans has fueled a lasting power-rate hangover for Portlanders. If they find the evidence, Leonard has vowed to bring PGE rates down, using a long-forgotten city ordinance that surfaced only recently. This article is not for distribution, please contact the publication directly. — The Tribune, Nick Budnick

January 30, 2006 Enron’s Legacy: Scandal Marked Turning Point for Business World; Impact Felt in Energy Trading, Lawsuits, Corporate Governance and Regulations “As Enron’s former top executives face criminal trial in Houston today, the legacy of Enron — the most sensational corporate fraud scandal in recent history — still ripples through the business world. ‘People are more circumspect because of the criminal convictions, but we’ve had very few substantive reforms,’ says Robert McCullough of energy consulting firm McCullough Research. This article is not for distribution, please contact the publication directly.” — USA Today, Edward Iwata January 23, 2006 Portland Signs on Three Experts to Scrutinize PGE Practices “Portland officials will dip into funds left over from the failed attempt to buy Portland General Electric to hire three energy experts for an investigation of the utility’s rate-setting practices. All are from the Portland area: Ann Fisher, a lawyer and consultant; Robert McCullough, a nationally recognized expert on wholesale power trading; and David Jubb, a lawyer and accountant. This article is not for distribution, please contact the publication directly.” — The Oregonian, Gail Kinsey Hill

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2005

September 28, 2005 Welcome to Gastoria The argument continues on whether new terminals should be build on the Columbia River near Astoria. While speculation rangers from terrorist threats to spoiled views and environmental concerns few can ignore the rising prices of Natural gas. The irony to all this is that despite all the hubbub over LNG terminals, we may not need them, says Robert McCullough, a Portland energy economist and former PGE executive who has been heavily involved in a number of high-profile energy fights. This article is not for distribution, please contact the publication directly. — Willamette Week, Nick Budnick July 28, 2005 Energy Bill Could Lead to More Public Power Oregon Public Broadcasting consults Robert McCullough regarding the potential repeal of the the Public Utility Holding Company Act. “Robert McCullough: When energy prices become uncontrollable and it’s impossible to audit private companies, the only solution is to find a governmental alternative. That’s why we have municipal utilities all the way up and sown the I-5 corridor.” –OPB, Ley Garnett

July 23, 2005 Power Grid Holds Up as Demand Escalates Robert McCullough comments on California plant shutdowns and the Stage 2 Emergency declared for Southern California on July 22, 2005. “A power plant voluntarily shutting down in California in late July is like Nordstrom closing shop the day before Christmas to paint its ceilings,” McCullough said. The California ISO is criticized for failing in advance to buy reserve power. — The San Diego Union-Tribune, Craig D. Rose

May, 2005 Power Play In an article about the California energy crisis and Enron’s market manipulations, Robert McCullough “warns that the gaming may not be over.” — Portland Monthly, Pamela Maclean

April 4, 2005 One False Move For years, investing legend David Bonderman could do no wrong. And then he tried to buy a utility from Enron. Like Enron before it, Texas Pacific misunderstood how different Oregon is from a place like Texas, says Robert McCullough, a former PGE executive who is now a utilities analyst.” — Fortune Magazine, Nicholas Varchaver

March 27, 2005 Grandma Millie, Meet the Detectives: An Unlikely Team Unmasks Enron A description of the investigation by Snohomish County Public Utility District No. 1 into market manipulation schemes discovered in taped recordings of Enron traders’ conversations. — LA Times, Jonathan Peterson

February 14, 2005 Higher power prices would harm industries here, study says Robert McCullough comments on the Bush administrations’s plan to raise rates in the Northwest. — Seattle Post-Intelligencer, Neil Modie

February 14, 2005 Study sees job cuts in power-rate plan “The proposed price increase would, in some ways, mimic the effects of skyrocketing prices witnessed during the West Coast energy crisis of 2000 and 2001, warned Robert McCullough, a Portland-based energy consultant who prepared the report. McCullough works for a number of private companies and utilities that buy power from the BPA. The crisis drove aluminum smelters to shut down and created havoc with the budgets of local utilities, driving up the bills of ratepayers. With many of the aluminum factories now gone, the brunt of the proposed price increases would be felt by other electricity-intensive industries such as chemical, steel and paper manufacturing, McCullough said. Oregon also would lose between 20,000 and 30,000 jobs, according to McCullough. — The Seattle Times, Warren Cornwall February 3, 2005 Script foretells Enron debacle “In one of the ironies of the Enron saga, company officials in February 2001 reviewed a script created by InnoVision Communications that depicted unscrupulous gas traders at work. The script even has one-time Enron Chief Executive Officer Jeff Skilling being handed a subpoena. “In hindsight, the script is unintentionally humorous,” Robert McCullough, managing partner of Portland, Ore.-based McCullough Research, told federal regulators in a filing this week.” — Houston Chronicle, David Ivanovich

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2004

June 5, 2004 Cal-ISO Issues Self-Criticism; State electricity agency admits in a report to questionable moves during the energy crisis. “Robert McCullough, an energy consultant and a Cal-ISO critic, applauded the admissions by Cal-ISO, which he described as “a bit of an apology” from a traditionally secretive group. ‘This is a very different document than anything we’ve ever seen from the California ISO,’ . . . . ‘I don’t think they were crooked. I think it was a situation of bad governance, not of bad ethics.’ — Los Angeles Times, Elizabeth Douglass June 3, 2004 Snohomish County, Wash., Utility Contends Enron Tapes Back Case for Refunds Robert McCullough comments on the effects of Enron’s criminal activities. “There was a set of criminal activities that was so aggressive that even the dullest and most honest people showed up around the edges.” — The Seattle Times, Christopher Schwarzen

February 18, 2004 Analysts like one post-Enron company; remain skeptical of the other “The question is how much economic value exists for these problem children,” said Robert McCullough, a forensic accountant and energy industry analyst who has combed through some of Enron’s convoluted finances. ‘In the absence of an arm’s-length transaction, valuation of these assets is dangerously speculative.'” — Associate Press, Kristen Hays January 12, 2004 ENRON TRIALS COULD CONCERN PGE CRIMINAL TRIALS OF FORMER EXECUTIVES MAY SHED NEW LIGHT ON THE PORTLAND UTILITY’S PAST ENERGY TRADING PRACTICES The article mentions Robert McCullough’s interest in following the Enron trials. — The Oregonian, Gail Kinsey Hill

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2003

December 30, 2003 Enron loses bid for SEC exemption Robert McCullough says. “For PGE to argue that it has a major trading operation and is primarily intrastate at the same time would certainly stretch the facts”. — The Seattle Times, Amy Strahan Butler

November 19, 2003 http://www.chron.com/ Robert McCullough comments on the purchase of Portland General Electric in November 2003. — Houston Chronicle, Eric Berger

September 19, 2003 Enron’s new revamp plan will pay more to creditors The article discusses Enron’s amended reorganization plan and speculation about how much Enron’s creditors would recover. — Chicago Tribune, Bloomberg News

August 15, 2003 Analysis: Blackout that’s sweeping across the Northeast, Midwest and parts of Canada Robert McCullough’s appeared on National Public Radio’s “Talk of the Nation” discussing the 2003 Northeast blackout. ‘Well, we’ve been here before. In 1965, we had a blackout about half this size that affected the same states and provinces. In that case, Congress and the Federal Power Commission, what’s now called FERC, took several months to get to the bottom of it. This is not the sort of situation where you can get on the Web and find an arrow. Someone has to walk through each piece of equipment in each utility. The timing is critical. The sheer complexity of it is unbelievable. Unlike the rest of the world, we have integrated the electric system from Saskatchewan to Florida, from New Orleans to Montreal, so it’s a big machine.’ — National Public Radio, Talk of the Nation, Neal Conan

February 26, 2003 Prices climb for power on spot market | Increases may eventually put pressure on retail rates “Robert McCullough was one of the first people to cite causes of the 2000 energy crisis. Robert McCullough, a Portland-based energy consultant who was among the first to argue that the market was rigged during the crisis, said natural gas prices are also being driven higher by a switch from the use of oil — whose price has also risen sharply — and stockpiling of natural-gas supplies. He agreed that hydropower is also in shorter supply than usual at this time.” — The San Diego Union-Tribune, Craig D. Rose

January 28, 2003 Enron Trial has Captive Audience in Oregon “When the capstone trial exploring Enron’s spectacular meltdown begins Monday in Houston, an extraordinary array of Portland-area residents will closely watch for new insights into the corporate debacle. Portland-based energy consultant Robert McCullough, who continues to advise clients on issues related to the 2000-01 power crisis, also says the high-profile trial could unloose new trading details.” — The Oregonian, Gail Kinsey Hill

January 3, 2003 Utilities Resume Power Trading: State ends two year run of electricity buying Robert McCullough comments on the state of California’s energy market. “Things may get stranger before they get better, but we are gradually returning to a normal world,” said Robert McCullough, a Portland, Ore.-based utility consultant who has studied California’s power crisis. — The Oakland Tribune, Daniel Taub

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2002

December 20, 2002 Big-ticket long-term power buy is upheld Robert McCullough comments on FERC’s obligation to West Coast consumers. “This is a situation when we have had energy traders who have pleaded guilty to wire fraud and energy firms that have settled court charges for enormous amounts, but FERC cannot find a connection between that and the overcharges,” McCullough said. — The San Diego Union-Tribune, Dean Calbreath

December 13, 2002 Overcharges in Calif. Estimated; Energy Firms Faulted, but $1.8 Billion Sum Is Less Than Sought Robert McCullough says FERC’s rulings are scattershot: “We have completely inconsistent rulings from different cases.” — The Washington Post, Peter Behr December 9, 2002 Settlement Reveals Another Enron Strategy The tactic, dubbed ‘Thin Man,’ comes out in a proposal between El Paso Electric and Federal Regulators. Robert McCullough says: “Thin Man didn’t get a lot of use because Fat Boy and other techniques designed to make the state grid operator think it was running out of electricity were more profitable”. . . . “The premise was to make sure the PX was always short.” — Los Angeles Times, Nancy Rivera Brooks

November 27, 2002 California Cal-ISO Says Enron Didn’t Force Blackouts “McCullough characterized Cal-ISO’s report as an attempt to spare itself embarrassment because of miscalculations. ‘They wrestled the gun away from Enron, pointed it at their own feet and started blazing away'” –Los Angeles Times, Nancy Rivera Brooks

November 12, 2002 A Big Victory by California in Energy Case “Robert McCullough, who runs an energy consulting firm in Portland, Ore., that has been investigating the California energy crisis for major energy users, said that, all in all, Williams appeared to be getting off relatively lightly. ”The value seems low to me,” he said. ”Williams had one of the biggest footprints in California. They appear all over the place with possible antitrust issues. So I’m not surprised they’d want to settle.” — New York Times, David Barboza

November 12, 2002 Marketplace News “Robert McCullough recently appeared on nationally broadcasted radio program “Marketplace” to give his thoughts on California energy markets. ‘The big profits were correlated to market abuses in California and neighboring regions. Now that the abuses have ended, no one seems to be able to make a dime.’ — National Public Radio(NPR), Marketplace, Steve Tripoli

October 21, 2002 Brazen Trade Marks New Path of Enron Probe The article is about trading manipulations by Enron’s Tim Belden. — Wall Street Journal, John R Wilke and Robert Gavin September 25, 2002 Dynegy to Settle Trading Charges; SEC – Gas Deals misled investors about trading activities Robert McCullough says “The good news is that one body of the federal government has investigated the quantity, but we’ve yet to get a report on the price issue.” — Chicago Tribune, Melita Marie Garza May 7, 2002 Memo Shows Enron Role in Hiking Prices Electricity: ‘Smoking gun’ document by company lawyers reveals tactics that helped create energy shortage in California last year “It’s one thing for economists to state that these things are happening. . . .It’s another thing for there to be internal documents on the table stating these things are happening [says Robert McCullough]. ” — Los Angeles Times, Nancy Rivera Brooks

May 6, 2002 Enron Knew Foreign Assets Had Declined Robert McCullough on Whitewing, one the financial creation that was designed to mislead investors– The Wall Street Journal, Rebecca Smith

May 5, 2002 Interview by Steve Curwood, Living on Earth Robert McCullough was interviewed on Living on Earth, regarding his testimony at the Senate hearings early in the Enron investigation. — National Public Radio, Living on Earth, Steve Curwood

February 1, 2002 Memos Show Enrons Hands in California Crisis Robert McCullough says that, “Enron traders deliberately tried to create the appearance of shortages and congestion, prompting declarations of power blackouts that need not have been called in some cases.” — Washington Post, Peter Behr

January 20, 2002 How 287 Turned Into 7: Lessons in Funny Math Robert McCullough comments on Enron and California: “We Don’t really know where reality sets in at Enron.” — New York Times, Gretchen Morgenson

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2001

June 1, 2001 Commodities Electricity Prices Fall on California Energy Crisis Robert McCullough comments about the effects of conservation and “voluntary relinquishing of supplies by companies that switched to market-based rates” in the Pacific Northwest: “Virtually all of the aluminum and titanium production and half the magnesium has shut. That’s 3,000 megawatts of load, and we’ve lost a lead smelter, chemical mill and paper mills.” — Dow Jones, Mark Golden

January 31, 2001 Huge Bets paved way to Enron’s downfall Robert McCullough says that Enron “showed some financial transaction going out 23 years, which is preposterous, of course. I call it pricing by rumor.” — Chicago Tribune, Flynn McRoberts

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2000

November 2, 2000 California Investigators Looking At WSCC Data On Generators “The California Public Utilities Commission, whose investigation of high prices in the wholesale power market continues, requested and received data this week on power production by independent generators in the state, according to the CPUC’s manager of the investigation, Steven Weissman. The CPUC got the data from McCullough Research, a consulting firm in Portland, Oregon, which has been claiming that independent generators have been gaming the system.” — Dow Jones Newswires, Mark Golden

July 26, 2000 Officials Probe Rising Cost Of Electricity “Amidst growing concern in the rise in prices, the Western Systems Coordinating Council refused to share its data on generation and transmission. Robert McCullough comments ‘Either everybody is way, way off on our forecasts and we’re headed for blackouts in August, or somebody is severely manipulating the market,’ Mr. McCullough says. ‘The only way to tell is to get this information and sift through it.'” — The Wall Street Journal, Rob Eure

February 9, 2000 BPA Plan for Power Lines Gets Static From Utilities Robert McCullough evaluates Bonneville Power Administration plans to create an nonprofit administrative organization to manage high-voltage electric lines, and the potential to increase costs. — The Wall Street Journal, Rob Eure

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email: Jean-Carl Ende
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