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Extract to table / objections-responses-second-data-request.docx
objections-responses-second-data-request.docx
Parties
HARKNESS LLP
Dunmore Energy Holdings Ltd
Dunmore Power Trading LLC
Dunmore Midstream Partners LP
Trader Inc
Dates
August 18, 2023
August 7, 2023
June 12, 2023
May 22, 2023
June 5, 2023
July 17, 2023
July 24, 2023
August 21, 2023
January 3, 2022
March 17, 2023
Amounts
$45,000
$120,000
$47.3
Obligations
No responsive information subject to such protections is being provided, and the withholding of any such information shall not be construed as an acknowledgment that responsive, non-privileged information does or does not exist
(b) Reliability-Must-Run Commitments
Two of DPT's generation units in the MISO footprint — the Greenfield Generating Station (Unit 3, 410 MW) and the Ashland Energy Center (Unit 1, 285 MW) — were subject to MISO reliability-must-run ("RMR") or system support resource ("SSR") arrangements during portions of the Relevant Period
Respondents maintain that these negative offers were entirely consistent with MISO's market rules, which expressly permit negative offers, and with the Commission's longstanding recognition that negative offers can reflect legitimate operational and economic considerations, particularly for generation units with significant minimum generation constraints, high startup costs, or contractual must-run obligations