Robert McCullough has testified extensively on energy issues across the United States and Canada, on behalf of clients and at the request of appointed and elected officials.
October 3, 2018
Robert McCullough’s affidavit in FERC case EL 16-49-000 regarding the PJM capacity market
Robert McCullough argues A properly calculated offer cap as part of the MOPR requirement is critical to preserve competitive results in the RPM auctions and to addresses market power.
February 10, 2016
Robert McCullough’s testimony before the Supreme Court of British Columbia on the costs and benefits of delaying Site C dam
Robert McCullough argues before the Supreme Court of British Columbia that a delay in the construction of the 1,100 MW Site C dam, requiring a delay in the in-service date, would amount to a net savings to British Columbia Hydro and its ratepayers, not a net cost. The net savings of a one year delay, in net present value terms, is $267.68 million; for a two year delay it is $519.44 million; for a five year delay, the net savings is $1,187.47 million. This result stems from low Mid-C prices, which are a competitive alternative to Site C.
August 24, 2015
Robert McCullough’s testimony to the New York State Public Service Commission on behalf of the New York State Legislative Assembly
In his testimony to the New York Public Service Commission, Robert McCullough argues against corporate secrecy in the New York Independent Systems Operator (NYISO). He shows that so-called confidential information on utilities’ wholesale electricity bids, financial data, and operational data is already widely available to the public, revealing NYISO generators’ masked bidding IDs in the process. Pending the Public Service Commission’s ruling on Case 11-M-0294, McCullough Research has posted only the redacted version of McCullough’s affidavit. Of course, interested parties are free to search for the “secret” information elsewhere on the web.
May 29, 2015
Robert McCullough’s testimony to the Federal Energy Regulatory Commission on behalf of Illinois Attorney General Lisa Madigan
Robert McCullough testified before the Federal Energy Regulatory Commission on behalf of Illinois Attorney General Lisa Madigan. In his affidavit he discusses market power in the Midcontinental Independent Systems Operator (MISO), following a tenfold price increase in MISO’s capacity auction in Illinois. McCullough identifies Dynegy, Inc. as the market’s pivotal supplier, which he writes is “effectively equivalent to a monopolist.”
December 15, 2014
Robert McCullough’s report to the Bureau d’audiences publiques sur l’environnment (BAPE)
In a report submitted to the BAPE on uranium mining in Quebec, McCullough writes, “this is a bad time to begin the experiment of regulation, safe closure, and extended monitoring for uranium projects in Quebec. The risk is high that foreseeable economic and environmental issues will overcome any economic benefits. This is an industry at risk, and it already has supplies for many, many years to come. Quebec does not need to gamble with its environment to support the uncertain future of nuclear power.”
July 20, 2010
Robert McCullough’s testimony to the Rhode Island Public Utility Commission on behalf of the Citizen Interveners Group
In Review of the Amended Power Purchase Agreement Between National Grid and Deepwater Wind Block Island McCullough testified, “The price for Deepwater Wind is high – significantly higher than similar projects recently completed or currently underway in Europe. Our knowledge of what we are actually purchasing is limited. The cost figures give the appearance of being reverse engineered from a required rate of return rather than derived from basic engineering estimates.”
March 25, 2009
Robert McCullough’s testimony to the U.S. Senate Subcommittee on Energy and Natural Resources
Robert McCullough appeared in Washington D. C. before the U. S. Senate Subcommittee on Energy and Natural Resources to discuss the state of oversight and transparency in energy markets in support of a draft legislation to improve energy market transparency and regulation.
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February 24, 2009
Robert McCullough’s testimony to the Connecticut Energy and Technology Committee on behalf of the AARP Connecticut
Robert McCullough testified in Hartford, Connecticut, on behalf of the AARP Connecticut chapter. H.B. No. 6510 (RAISED) AN ACT ESTABLISHING A PUBLIC POWER AUTHORITY is another effort by consumer advocates, Attorney General Blumenthal and others to protect the people of Connecticut and the state economy from the predatory pricing resulting from ISO New England’s single price wholesale electricity auction market.
September 16 , 2008
Robert McCullough’s testimony to the U.S. Senate Committee on Energy and Natural Resources
Robert McCullough testified to the U.S. Senate Committee on Energy and Natural Resourceson September 16, 2008 to discuss the the role of speculative investment in energy markets.
See the report here.
April 11, 2007
In the Court of Appeals of the State of Oregon; WAH CHANG V. PACIFICORP
The attached order references Robert McCullough’s affidavit filed in opposition to a previous summary judgment.
May 8, 2006
Prepared Testimony to the Democratic Policy Committee on Regulation and Forward Markets: Lessons from Enron and the Western Market Crisis
Transcript of Testimony
Report on Regulation and Forward Markets
Robert McCullough testified in front of the Democratic Policy Committee for the oversight hearing on Energy Trading and Gas Prices. He examined the effects of the Western Energy Market Crisis on forward electric and gas markets.
Supporting materials are listed here by corresponding footnote:
Footnote 3 Footnote 4 Footnote 5 Footnote 6 Footnote 8
Footnote 10 Footnote 11 Footnote 12 Footnote 14 Footnote 15
Footnote 16 Footnote 17 Footnote 18 Footnote 20A Footnote 20B
Footnote 21 Footnote 22 Footnote 23 Footnote 25 Footnote 26
Footnote 27 Footnote 28 Footnote 29 Footnote 30 Footnote 35
Footnote 37 Footnote 38 Footnote 39 Footnote 40 Footnote 41
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Footnote 48 Footnote 49 Footnote 51 Footnote 52 Footnote 54
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Footnote 60 Footnote 61 Footnote 62
May 13, 2005
Rebuttal Testimony of Robert McCullough on behalf of Snohomish Public Utility District No. 1
Rebuts the direct testimony filed by Enron witness Jan Paul Acton, involving Enron’s gaming practices and profits.
January 27, 2005
Prepared Supplemental Testimony of Robert McCullough on Behalf of Snohomish Public Utility District No. 1
Summarizes new evidence, expounds upon previous findings and recommends that the appropriate remedy is not to attempt to calculate specific profits, but to eliminate Enron’s market pricing privilege from the beginning of the scope of this case.
February 24, 2004
Prepared Direct Testimony of Robert McCullough on Behalf of Snohomish Public Utility District No. 1
Presents evidence of Enron’s gaming practices and the partnerships, alliances, and arrangements made by Enron with other entities to facilitate the trading schemes.
March 20, 2003
Prepared Rebuttal Testimony of Robert McCullough on Behalf of the City of Seattle, WA
By means of a comparison between the load/resource conditions in the WECC and California in 1999 and 2000-2001, Robert McCullough shows how price increases in 2000 and 2001 in the WECC and Caifornia markets must be attributed to factors other than: (1) low energy reserves; (2) low capacity; or (3) a significant increase in peak loads. Mr. McCullough shows that the dramatic price increases that occurred from May 2000 to June 2001 cannot be explained by a supply and demand imbalance caused by a hydroelectric shortage coupled with increased demand.
March 3, 2003
Prepared Direct Testimony of Robert McCullough on Behalf of City of Tacoma, WA and Port of Seattle
This testimony was a key factor in proving to the Federal Energy and Regulatory Commission (FERC) that spot prices influenced forward prices. Robert McCullough explains and gives examples of generators withholding power and power marketers’ gaming of energy market during the Western Market Crisis of 2000-2001. FERC then found that the manipulation caused unreasonably high prices and has ordered refunds to entities which bought spot power.
October 7, 2002
Rebuttal Testimony of Robert McCullough on Behalf of Snohomish Public Utility District No. 1
Rebuts Kalt, Hogen and Harvey.
June 25, 2002
Prepared Direct Testimony of Robert McCullough on behalf of Snohomish Public Utility District No. 1
Describes recently discovered manipulation of the California Power Exchange (PX) and the California Independent System Operator (CAISO) that raised prices and increased the costs to consumers throughout the Western Systems Coordinating Council in 2000 and 2001.
April 11, 2002
Testimony of Robert McCullough before the U.S. Senate Committee on Commerce, Science, and Transportation
An analysis of the California energy crisis.
February 13, 2002
Testimony of Robert McCullough before the Subcommittee on Energy and Air Quality
Testimony on the California energy markets.
January 29, 2002
Testimony of Robert McCullough before the U.S. Senate Committee on Energy and Natural Resources
Testimony on the need for transparency in energy markets.
August 30, 2001
Rebuttal Testimony of Robert F. McCullough on behalf of Seattle City Light
Rebuts various witnesses on behalf of Transaction Finality Group.
August 16, 2001
Prepared Direct Testimony of Robert F. McCullough on behalf of Seattle City Light
Robert McCullough addresses the calculation of a fair and reasonable rate for the Pacific Northwest including the appropriate definition of spot purchases that are suitable for refund and the appropriate marginal production cost to be used in the computation.
June 12, 2001
Rebuttal Testimony of Robert McCullough on behalf of Wah Chang
Rebuttal to PacifiCorp witnesses Tallman and Griffith.
April 17, 2001
Testimony of Robert McCullough on behalf of Wah Chang
Explains the failure of centrally directed “market prices” in California and the resulting effects of price volatility on power purchases.
March 3, 2001
Prepared Direct Testimony of Robert McCullough on Behalf of the City of Tacoma, WA and the Port of Seattle, WA
Describes several trading schemes used during the California Western Market Crisis.