Contract analysis

I. Introduction and Purpose of Letter I am Catherine Bloom, a partner in the Energy Enforcement and Investigations practice group at Calderwood & Harkness LLP ("Calderwood & Harkness" or "C&H"). I write on behalf of our clients, Dunmore Energy Holdings Ltd. ("DEH" or "Dunmore") and its wholly owned subsidiary, Dunmore Power Trading LLC ("DPT"), in response to the preliminary inquiry letter issued by the Federal Energ

II. Confirmation of Intent to Cooperate Dunmore and DPT are committed to full, good-faith cooperation with FERC's Office of Enforcement throughout the course of this inquiry. Dunmore takes any inquiry from the Commission with the utmost seriousness and has the highest respect for the Commission's oversight role in ensuring the integrity and transparency of the nation's wholesale energy markets. Immediately upon recei

III. Overview of Dunmore Energy Holdings Ltd. To provide OE Staff with useful context for evaluating DPT's trading activity, we set forth below a summary of DEH's corporate structure, business operations, ownership, and relevant affiliated entities. A. Corporate Structure and Jurisdiction Dunmore Energy Holdings Ltd. is an exempted company incorporated and existing under the laws of the Cayman Islands. DEH's register

IV. Overview of Dunmore Power Trading LLC A. Entity Information Dunmore Power Trading LLC is a Delaware limited liability company and a wholly owned subsidiary of DEH. DPT's registered agent is Capitol Registered Agents Inc., located at 1209 Orange Street, Wilmington, Delaware 19801. DPT's principal office is co-located with DEH at 2200 Post Oak Boulevard, Suite 3100, Houston, Texas 77056. DPT's U.S. Employer Identif

V. Prior Regulatory Counsel Dunmore wishes to inform OE Staff that its prior outside counsel for FERC regulatory matters, including MBR filings, tariff compliance, and general regulatory advice, has been Aldercroft & Beane LLP, located at 1875 K Street NW, Suite 600, Washington, D.C. 20006. The principal attorney at that firm responsible for Dunmore's FERC matters was Warren Aldercroft, Named Partner. Upon receipt of

VI. Proactive Compliance Measures Dunmore wishes to bring to the Commission's attention that it has taken significant proactive steps to enhance its compliance program, independent of and well in advance of the issuance of the preliminary inquiry letter. Specifically, on February 6, 2023 — more than three months before the date of the preliminary inquiry letter — Dunmore appointed Jennifer Caulfield, age 47, as Chief

VII. Requests for Clarification Dunmore respectfully submits the following requests for clarification regarding the scope and procedural aspects of OE's preliminary inquiry. Dunmore raises these requests in a spirit of cooperation, with the goal of ensuring that Dunmore's responses to OE Staff's information needs are targeted, comprehensive, and efficient. A. Scope of the Inquiry The preliminary inquiry letter dated

1. Pricing Nodes. The inquiry letter references activity in the MISO Day-Ahead and Real-Time energy markets generally. Dunmore seeks confirmation of whether the inquiry is limited to DPT's trading activity at Indiana Hub (MISO pricing node) and Minnesota Hub (MISO pricing node), or whether the inquiry extends to DPT's activity at other pricing nodes within the MISO footprint. Clarification on this point will enable D

2. Time Period. The inquiry letter references trading activity during the period beginning January 2022. Dunmore requests confirmation of the end date of the period under review. Based on the language of the inquiry letter and certain follow-up communications, Dunmore understands that the period may extend through approximately March 2023. Confirmation of the precise end date will assist Dunmore in ensuring that its

3. Affiliated Entities. Dunmore requests confirmation of whether the inquiry extends to the activities of affiliated entities beyond DPT, and in particular whether OE Staff's inquiry encompasses the activities of Dunmore Midstream Partners LP. As noted in Section III.D above, DMP's pipeline infrastructure supplies natural gas to several of Dunmore's gas-fired generation plants, and DMP's operations may therefore be r

4. Products and Transaction Types. Dunmore requests clarification regarding the specific products or transaction types that are the subject of the inquiry. In particular, Dunmore seeks confirmation of whether the inquiry encompasses: (a) Day-Ahead generation offers submitted by DPT for Dunmore's physical generation resources; (b) virtual transactions (Increment Offers and Decrement Bids) submitted by DPT in the MISO

VIII. Dunmore's Independent Auditor For purposes of completeness, and to the extent it may be relevant to OE Staff's inquiry, Dunmore notes that its independent auditor is Prescott & Hargrove LLP, located at 700 Louisiana Street, Suite 3500, Houston, Texas 77002. The engagement partner responsible for Dunmore's audit is Douglas Fenn, CPA. Prescott & Hargrove has served as Dunmore's independent auditor since fiscal ye

IX. Point of Contact and Next Steps Dunmore respectfully requests that all correspondence, communications, data requests, and other inquiries regarding this matter be directed to the following individuals: Catherine Bloom, Partner Calderwood & Harkness LLP 1001 Fannin Street, Suite 4200 Houston, Texas 77002 Telephone: (713) 555-8412 Email: cbloom@calderwoodharkness.com With copies to: Hannah Brinkley, Associate Calde

1. The scope of the inquiry, including the specific pricing nodes, time period, affiliated entities, and transaction types that are the subject of OE Staff's review;

2. The format, timing, and sequence of any document requests or data requests that OE Staff anticipates issuing;

3. Procedures for the production of documents and data, including any preferences OE Staff may have regarding production format, Bates numbering conventions, and privilege log protocols;

4. Confidentiality protections and the potential terms of a protective agreement governing the treatment of sensitive materials;

5. The availability of Dunmore personnel for interviews or informal discussions with OE Staff; and

6. Any other procedural matters that OE Staff wishes to discuss at the outset of the inquiry. Dunmore reiterates its commitment to full, transparent, and good-faith cooperation with the Commission's Office of Enforcement throughout this process. Dunmore believes that a cooperative approach will promote the efficient resolution of this inquiry and will enable OE Staff to obtain a complete and accurate understanding of